Rev. Rul. 66-163

The Internal Revenue Service has reconsidered Revenue Ruling 60-39, C.B. 1960-1, 406, as it relates to certain articles variously referred to as `slide-in cabins' or `pickup coaches,' etc., designed to be mounted or placed upon pickup trucks, and described in situations (1) and (2) of that ruling. These articles are intended to be used as temporary or long-term living quarters and are usually equipped for sleeping and eating purposes. Revenue Ruling 60-39 held these articles to be taxable under section 4061(a)(1) of the Internal Revenue Code of 1954, as automobile truck bodies.

Section 4061(a)(1) of the Code imposes a tax on the sale by the manufacturer, producer, or importer of certain enumerated motor vehicle articles. Included in this enumeration are automobile truck bodies. Section 4061(b) of the Code imposes a tax on the sale by the manufacturer, producer, or importer of parts or accessories (other than tires or inner tubes) for any of the articles enumerated in section 4061(a) of the Code.

In the case of King Trailer Company v. United States , 350 Fed. (2d) 947 (1965), the United States Court of Appeals for the 9th Circuit affirmed a District Court decision holding `pickup coaches' are neither truck bodies nor truck parts or accessories. The Service recognizes this decision as a precedent in the diposition of other cases involving such articles.

Revenue Ruling 60-39 is hereby modified.