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B-178453 1 (1973-06-14)

handle is hein.gao/gaobaadbr0001 and id is 1 raw text is: 


.~ COMPTROLLUR D1RAL o aTH; UNITED SrATI
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        5-178453
                                                    June 14, 1973
                     II
        Mt. Lavrence'To. Wat
        Authorized Cert.fying Officer
        Internal Rovenue Service
        lntted States Traiury Department
        PO Box 926
        Atlanta, eorgia 30301

        Dear Hr, Wensti
            Thi* refers to your latter of eartch 19, 19?3, reference A.TP;sb,
        requestinguan advance decision an to the legaliijy of a clam presente4
        by Hr. JLwellyn B, Trimer, an employee o the Interna lPenua Service,
        The item qusutloned appears on the voucher sulatted with your letter
        'and usA  in the anount of $416,#48, representius th sales tax on a mobile
        home purchased Incident to a travsfer of official' Atation fr CYTurn,
        Arizona, to Fort Pierce, Florida, effective Harh 7. 1972.
            Subsection 492d of Offlet of ansgemnt and Budget (O) Circular
        No. A-56 allows payment of riortgaae and transfer taiss pin real estate
        transactions otherwise reimbursable under provisions of tho statutory
        regulation. In essence, you question whother the ales tax paid by
        Hr. TrJznr is a transfer tax within the eaning of the regu3ation.

            Pertinent provisionu of the Florida evene Act of 1949,
        chapter 212, and chapter 320, Florida statutes, 1971 edition, ares

                 212.02 'Defirtiton.--The followins te'vme and
            phrases when used in this chapter, shall hewn the
            meaning ascribed to thm in this section, ecept
            %here the context clearly indicatee a different



                 (2) Sal t ans and includes:

                 (a) Any transfer of title or posnession, or
            both, exchange, barter, lease or rental, conditional
            or o~herwise, in any manner or by any mean vnatsoever
            of tangible personal property for a consideration;



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