Rev. Rul. 65-211

The Redevelopment Authority of the City of Philadelphia was created under the laws of the Commonwealth of Pennsylvania to plan and manage the redevelopment of certain `blighted areas' because dwellings therein were unsafe, unsanitary, and overcrowded. The redevelopment activities are designed to promote public health, safety, and welfare.

The statute creating the Authority provides that it is a public body, corporate and political, exercising public powers of the Commonwealth as an agency thereof. Under that statute, the Authority is empowered to provide and maintain parks, recreational centers, schools, and sewerage, transportation, and water facilities. It has authority to acquire real property by eminent domain and to zone or rezone any part of the municipality in connection with its redevelopment proposals.

Held , the described Authority is a `political subdivision' of a State for purposes of the exemption from documentary stamp tax provided by section 4362(b) of the Internal Revenue Code of 1954. Accordingly, the Authority is not liable for the documentary stamp tax imposed by section 4361 of the Code with respect ot any conveyance of realty sold. However, nonexempt parties to the conveyance are liable for the tax under the dual liability provisions of section 4384 of the Code.