Rev. Rul. 64-303

A company manufactures and sells a product which serves as a remote control for a device which opens and closes garage doors automatically. The product consists of two units, a radio transmitter and a radio receiver. The transmitting unit may be mounted in an automobile, or operated from a carrying case either within or outside an automobile. It is powered by a 15-volt dry cell battery. The receiving unit operates on standard electric house current and is attached to the door opening and closing device installed in a garage. The receiver is capable of receiving only relay control signals on a frequency of 27.255 megacycles within the citizens radio service band. Held , manufacturers' sales of the described transmitter and receiver, whether in combination or as separate units, are not subject to either the manufacturers excise tax on automobile `parts or accessories,' imposed by section 4061(b) of the Internal Revenue Code of 1954, or the manufacturers excise tax on radio and television articles imposed by section 4141 of the Code.