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TREASURY DEPARTMENT Washington,April,23,1915 Office of Commissioner of Internal Revenue M. C. Elliott, Esq., Counsel, Federal Reserve Board, Treasury Department, Washington, D* C. S I R ; This office is in receipt of your letter of the 17th instant propounding a number of inquiries concerning the application of the Act of October 22, 1914, to various documents required under t h e ‘operations of the Federal Reserve Act* Answers follow herewith numbered in accord ance with the numbers given by ycu'to tho questions con tained in your said letter. (1) While this office understands them to be required by express provision of the Federal Reserve Act, certificates made to the Comptroller of the Currency by Federal Reserve Banks showing increases or decreases in capital stock, appear to fall directly within the exemption contained in the paragraph of T. D. 2087 issued by this office, entitled "Certificates for use of the Government," covering among other documents "Reports made to the Comp troller of the Currency." It is therefore held that no tax stamps are required on these certificates. (2) Certificates net required by any express provision of la., but merely under the regulations of the -2- M. C. Elliott, Esq., 865 Federal Reserve Board acting under general authority con ferred by law are not subject to tax under the Act here in question. In this connection attention is invited to the first two paragraphs cf T. D. 2087, ropy of which is enclosed herewith. (3) It b eing the understanding of this office that Federal Reserve Banks are held tc occupy the status of private rather than public institutions, certificates of stock when issued by them, are held to be subject to tax under paragraph 1 of schedule A of the Act of October 22, 1914, imposing taxation in the amount of five cents per §100 cf face valu$ or fraction thereof, upon original issue of certificates of stock by any company, association or corporation. This office holds the face value of such certificates to be the par or nominal value of the stock covered thereby, even, though the certificates show upon their face that only part of the full yrice has been paid therefor, (4 <x 5) This office is aware of no provision of law under which ta* could be imposed upon interim receipts given by Federal Reserve Banks for individual assessments on stock subscriptions^ Respectfully, (Signed) W. H, OSBORN, Commissioner. 4/24/15/
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