B-89913, NOVEMBER 8, 1949, 29 COMP. GEN. 213

B-89913: Nov 8, 1949

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WHICH ARE ADAPTATIONS OF PANEL TRUCKS. DIFFERING THEREFROM ONLY IN THAT WINDOW OPENINGS ARE BUILT INTO THE OTHERWISE SOLID METAL SIDE PANELS AND REMOVABLE SEATS ARE INSTALLED. 1949: REFERENCE IS MADE TO LETTER OF OCTOBER 13. CONCERNING THE ADMINISTRATIVE DIFFICULTIES WHICH HAVE BEEN ENCOUNTERED IN THE MOTOR-VEHICLE IMPROVEMENT PROGRAM ON ACCOUNT OF THE HYBRID NATURE OF "SUBURBAN CARRYALLS.'. IT IS STATED BY THE ASSISTANT DIRECTOR THAT THERE HAS BEEN A TENDENCY BY SOME TO CONSIDER THESE VEHICLES AS TRUCKS. DEPENDING UPON WHETHER THE VEHICLE IS USED TO HAUL PROPERTY OR WHETHER IT IS USED TO TRANSPORT PASSENGERS. THE LITERATURE ENCLOSED WITH THE AFORESAID LETTER INDICATES THAT THE SUBURBAN CARRYALL IS ACTUALLY AN ADAPTATION OF A PANEL TRUCK.

B-89913, NOVEMBER 8, 1949, 29 COMP. GEN. 213

VEHICLES - "SUBURBAN CARRYALLS" - CLASSIFICATION AS TRUCKS "SUBURBAN CARRYALLS" CONSTRUCTED IN CONFORMITY WITH TRUCK SPECIFICATIONS, WHICH ARE ADAPTATIONS OF PANEL TRUCKS, DIFFERING THEREFROM ONLY IN THAT WINDOW OPENINGS ARE BUILT INTO THE OTHERWISE SOLID METAL SIDE PANELS AND REMOVABLE SEATS ARE INSTALLED, MAY BE CLASSIFIED AS TRUCKS FOR MANAGEMENT, BUDGET, AND ACCOUNTING PURPOSES, EVEN THOUGH SUCH VEHICLES MAY BE USED FOR PASSENGER-CARRYING PURPOSES.

COMPTROLLER GENERAL WARREN TO THE DIRECTOR, BUREAU OF THE BUDGET, NOVEMBER 8, 1949:

REFERENCE IS MADE TO LETTER OF OCTOBER 13, 1949, FROM THE ASSISTANT DIRECTOR, BUREAU OF THE BUDGET, CONCERNING THE ADMINISTRATIVE DIFFICULTIES WHICH HAVE BEEN ENCOUNTERED IN THE MOTOR-VEHICLE IMPROVEMENT PROGRAM ON ACCOUNT OF THE HYBRID NATURE OF "SUBURBAN CARRYALLS.'

IT IS STATED BY THE ASSISTANT DIRECTOR THAT THERE HAS BEEN A TENDENCY BY SOME TO CONSIDER THESE VEHICLES AS TRUCKS, WHILE OTHERS CONSIDER THEM AS PASSENGER VEHICLES, DEPENDING UPON WHETHER THE VEHICLE IS USED TO HAUL PROPERTY OR WHETHER IT IS USED TO TRANSPORT PASSENGERS. HOWEVER, BUDGET INSTRUCTIONS PROVIDE THAT, FOR REPLACEMENT PURPOSES, THE VEHICLES BE CLASSED AS TRUCKS.

THE LITERATURE ENCLOSED WITH THE AFORESAID LETTER INDICATES THAT THE SUBURBAN CARRYALL IS ACTUALLY AN ADAPTATION OF A PANEL TRUCK, AND EXCEPT THAT IT HAS REMOVABLE SEATS, THE PRIMARY DIFFERENCE CONSISTS OF THE TWO WINDOW OPENINGS ON EACH SIDE OF THE VEHICLE AS COMPARED TO THE SOLID STEEL PANELS IN THE PANEL TRUCK. THE BODY OF THE SUBURBAN CARRYALL IS MOUNTED ON A TRUCK CHASSIS AND IS SOLD AS A UNIT. OTHER ENGINEERING DATA MADE AVAILABLE INFORMALLY BY A REPRESENTATIVE OF YOUR AGENCY DISCLOSE THAT THE STRUCTURAL DESIGN OF THE VEHICLE CONFORMS TO TRUCK SPECIFICATIONS. CONSEQUENTLY, THOUGH SUCH SUBURBAN CARRYALLS MAY AT TIMES BE USED FOR PASSENGER-CARRYING PURPOSES, PASSENGER-RIDING QUALITY IS SACRIFICED TO PROVIDE TRUCK STURDINESS.

ACCORDINGLY, IT APPEARS THAT SUCH VEHICLES ARE CONSTRUCTED PRIMARILY FOR TRUCKING PURPOSES AND, IN VIEW OF THE OBVIOUS CONFUSION RESULTING FROM A CLASSIFICATION BASED UPON USAGE RATHER THAN CONSTRUCTION, YOU ARE ADVISED THAT THIS OFFICE WOULD NOT BE REQUIRED TO OBJECT IF THE VEHICLE DESCRIBED IN THE LETTER OF OCTOBER 13, 1949, BE CLASSIFIED AS A TRUCK FOR MANAGEMENT, BUDGET, AND ACCOUNTING PURPOSES.