PLR 200039030: IRS revokes an earlier air transportation excise tax ruling

Plain-English summary

The IRS notified a taxpayer that it was revoking a 1980 letter ruling about the excise tax on air transportation of persons under § 4261. It cited the revocation procedure in Revenue Procedure 2000-1 and set October 1, 2000, as the effective date. The letter does not give a reason for the revocation or explain the earlier ruling's conclusions. It therefore establishes the status of that taxpayer's prior ruling, but does not resolve a new air transportation tax question in the released text.

Ruling snapshot

• Question: What is the status of the taxpayer's earlier § 4261 letter ruling?
• Outcome: Revocation effective October 1, 2000.
• Key authorities: IRC § 4261; Rev. Proc. 2000-1 § 12.04.

Full text (IRS public release)

INTERNAL REVENUE SERVICE

Number: 200039030
Release Date: 9/29/2000
Index No.: 4261.00-00

CC:DOM:P&SI:8/PLR-112181-00

JUN 30, 2000
In re:

Legend:

Taxpayer =

Dear . :

On November 14, 1980, the Internal Revenue Service (IRS) issued a letter ruling, LTR 8106055, to Taxpayer concerning the excise tax on the air transportation of persons imposed by § 4261 of the Internal Revenue Code.

In accordance with section 12.04 of Revenue Procedure 2000-1, 2000-1 I.R.B. 4, 46, the IRS is revoking LTR 8106055. The effective date of the revocation is October 1,
2000. Section 6110(k)(3) provides that this document may not be used or cited as
precedent.

                                      Sincerely,

                                      Assistant Chief Counsel
                                      (Passthroughs and Special Industries)


                                By:
                                      Ruth Hoffman
                                      Senior Technician Reviewer, Branch 8

Enclosures (2):

Copy of this letter
Copy for § 6110 purposes