Rev. Rul. 65-151

Pursuant to a change in its form of operation from partnership to corporation, a stock brokerage firm, with the express or tacit consent of its customers, transferred its customers' security accounts from the partnership to the successor corporation, or its registered nominee. The successor corporation holds the customers' securities involved in the transfer in the same capacity as they were held by the partnership. Held , the described transactions are in effect transfers between customers and brokers and, under the provisions of sections 4322(a)(1) and 4332(a) of the Internal Revenue Code of 1954, the documentary stamp taxes imposed by sections 4321 and 4331 of the Code do not apply to the described transfers, providing they are accompanied by exemption certificates as required by section 4345 of the Code.