26 U.S.C. § 4181
Section 4181 · Imposition of tax
Amended 1 time on record
Applied in 26 court decisions — leading case Wnuck v. Commissioner (2011)
Most recently applied in Fitzgerald Truck Parts & Sales LLC v. United States (March 2025)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
There is hereby imposed upon the sale by the manufacturer, producer, or importer of the following articles a tax equivalent to the specified percent of the price for which so sold:
Articles taxable at 10 percent—
Pistols.
Revolvers.
Articles taxable at 11 percent—
Firearms (other than pistols and revolvers).
Shells, and cartridges.