Tax file

The IRS chief counsel recently ruled on the taxability of a pickup truck that was extensively modified to pull full-time house trailers and horse trailers. Although “trucks,” which have onboard cargo space, are not subject to the 12% excise tax on new vehicles unless their gross vehicle weight rating (GVWR) exceeds 33,000 lb., “tractors” of any weight are taxable. This vehicle had two cargo boxes on the chassis and a GVWR of 23,000 lb. However, the IRS ruled that the boxes constituted minimal cargo-carrying capacity and the vehicle's modifications clearly meant it was designed principally for towing cargo, making it a taxable tractor. The ruling, Private Letter Ruling 200119024, applies only to that taxpayer, but many other rigs could be affected.