Rev. Rul. 66-88

Revenue Ruling 59-282, C.B. 1959-2, 332, holds that the sale of a production payment retained from the assignment of an interest in oil, gas and minerals in place is a conveyance of realty sold within the meaning of section 4361 of the Internal Revenue Code of 1954 and is subject to documentary stamp tax imposed under that section. The principal of that ruling is equally applicable to a transaction of the kind commonly described and known in the industry as the conveyance of a carved-out production payment. Held , the conveyance of a carved-out production payment is subject to the documentary stamp tax imposed by section 4361 of the Code.

Revenue Ruling 59-282 is hereby amplified.