Rev. Rul. 57-458

The transportation movement of standard density bales of cotton, which are in the course of exportation by reason of having been shipped pursuant to an export contract, particular charges, will be applied of having the cotton compressed to high density bales in accordance with requirements of the transoceanic steamship lines. Such compression does not enhance the value of the cotton or serve any other business purpose except as an accommodation to the means of transportation. Held , such stoppage does not constitute a `break' in the continuity of the export movement of the cotton for a business purpose within the meaning of section 143.31 of Regulations 113, made applicable to the Internal Revenue Code of 1954 by Treasury Decision 6091, C.B. 1954-2, 47. Accordingly, the amount paid for the transportation of the cotton from the point of origin to the place where the bales are compressed is exempt from the excise tax on transportation of property imposed by section 4271(a) of the Code, provided the person paying the transportation charges establishes exemption from payment of the tax in accordance with the applicable provisions of subpart E of Regulations 113.