Rev. Rul. 64-242

A company located within the United States imports and sells automobiles of foreign manufacture. Subsequent to sale of the automobiles in the United States, the company reacquires title to some of the engines contained in the automobiles after they have been rendered unserviceable through use. The company ships these engines to the foreign manufacturer to be `rebuit,' as that term is used in section 48.4061(b)-3(a) of the Manufacturers and Retailers Excise Tax Regulations. The rebuilt engines are brought back into the United States by the company for sale. Held , the rebuilt engines are subject to the manufacturers excise tax on automobile `parts or accessories,' imposed by section 4061(b) of the Internal Revenue Code of 1954, when sold by the company.