Rev. Rul. 72-260

A United States person, as defined in section 4920(a)(4) of the Internal Revenue Code of 1954, purchased stock of a foreign corporation. The acquisition of such stock was subject to interest equalization tax under section 4911 of the Code. Included in the purchase price of such foreign stock were the payment of a foreign stamp tax and commissions.

Held, the "actual value" of the foreign stock for purposes of the interest equalization tax imposed on such value under section 4911 of the Code does not include the foreign stamp tax and commissions paid on such stock.