Ezel / IRS Rulings / 200125033

PLR 200125033: IRS withdraws earlier farm trailer excise tax ruling

Number
200125033
Outcome
Revocation
Document type
Private Letter Ruling
IRS subject
Exemptions
Topics
Excise taxes
Code sections
§ 4051, § 4053
Ruling dated
March 20, 2001
Publicly released
June 22, 2001
Source
View Official PDF

Apply this to your situation

This page covers one taxpayer's ruling, issued in 2001, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2001
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

The IRS told a taxpayer that it was reconsidering whether certain semitrailer bodies qualify for the federal excise tax exception for equipment designed to transport and unload feed, seed, or fertilizer on a farm. A 1985 letter had concluded that one open box trailer body qualified for the exception and was outside the tax on retail sales of semitrailer bodies. The IRS withdrew that earlier letter effective April 1, 2001, so the taxpayer could no longer rely on it after March 31. This notice did not state a new conclusion about the trailer body's tax treatment.

Ruling snapshot

  • Question: Could the taxpayer continue relying on its 1985 excise tax exemption letter?
  • Outcome: Revocation: the earlier letter was withdrawn effective April 1, 2001.
  • Key authorities: IRC §§ 4051(a), 4053(2).

Full text (IRS public release)

INTERNAL REVENUE SERVICE

Number: 200125033
Release Date: 6/22/2001
Index No.: 4053.00-00

CC:PSI:8/PLR-113314-01

MAR 20, 2001
In re:

Legend:

Taxpayer =

Dear

This letter is notification that the Internal Revenue Service (IRS) is reconsidering the applicability to certain semitrailer bodies of the feed, seed, and fertilizer equipment exception in § 4053(2) of the Internal Revenue Code.

On April 19, 1985, IRS issued a letter ruling (LTR - 8529027) involving Taxpayer.
LTR - 8529027 concluded that Taxpayer’s retail sale of an open box trailer body was not subject to the tax imposed by § 4051(a) of the Code because the open box trailer body was primarily designed to transport feed, seed, or fertilizer to a farm, and to unload the feed, seed, or fertilizer on the farm as described in § 4053(2). This open box trailer body had a chain link conveyor system, a floor that sloped from front to rear, a fully removable top, a hydraulically operated metering door, a fully opening rear door, a rear conveyor seal, a hydraulic flow control valve, and a self-contained gasoline/hydraulic power unit to power the unloading system.

Because this matter is now being reconsidered, the IRS is withdrawing LTR - 8529027 effective April 1, 2001. Consequently, Taxpayer may no longer rely on LTR - 8529027 after March 31, 2001.

If you have any questions concerning this withdrawal, please contact

Sincerely,
Associate Chief Counsel
(Passthroughs and Special Industries)
By: Richard A. Kocak
Chief, Branch 8

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