Rev. Rul. 57-170

Subsidiary branches of a State humane society, which society was created as a body corporate under the authority of State law, are empowered to act in the furtherance of certain governmental functions. They are vested with special police powers in the enforcement of the law concerning the prevention of cruelty to children and animals. Certain public funds are appropriated to the use of these societies in performing their statutory functions. Salaries of certain agents of the societies who are designated as public law enforcement officers are paid in part by counties or municipalities. Held, such humane societies are instrumentalities of political subdivisions of a State within the meaning of sections 4055, 4224, and 4292 of the Internal Revenue Code of 1954. Accordingly, the retailers and manufacturers excise taxes imposed under chapters 31 and 32, respectively, of the Code, do not apply to sales made to such societies. Also, the taxes imposed by sections 4251, 4261, and 4271 of the Code do not apply to payments for communication and transportation services or facilities furnished to the societies or to payments for the transportation of property to or from such societies.