Rev. Rul. 71-220

A real estate investment trust developed a mobile home community on land that it had purchased. The mobile home community was situated in a planned site that had a country club, marina, parks, churches and schools. When the units were delivered to the site they were set on foundations consisting of pre-engineered blocks. The wheels and axles were removed from the unit, and the unit was affixed to the ground by six or more steel straps. A carport or screened porch was attached to the unit. The unit was connected to water, sewer, gas, electric and telephone facilities. The real estate investment trust leased the individual home sites to the mobile homeowner and issued debt instruments to individuals for the purpose of purchasing mobile home units. The real estate investment trust did not sell mobile homes.

Held, the mobile home units are "real property" within the meaning of section 856 of the Internal Revenue Code of 1954 and section 1.856-3(d) of the Income Tax Regulations. Held further, to the extent that the notes of borrowers are secured by real property they shall be considered as obligations secured by mortgages on real property or on interests in real property within the meaning of section 856 of the Code.