Ezel / IRS Rulings / 200149012

PLR 200149012: IRS revokes an earlier communications excise tax ruling

Number
200149012
Outcome
Revocation
Document type
Private Letter Ruling
IRS subject
Definitions
Topics
Excise taxes
Code sections
§ 4251, § 4253
Ruling dated
August 27, 2001
Publicly released
December 7, 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 revoked a 1985 letter ruling about whether certain communications services were exempt from the excise tax imposed by § 4251 under § 4253(f). The revocation took effect October 1, 2001. This letter identifies the prior ruling as LTR 8529094 but gives no facts about the services and no substantive reason for the revocation. It cites the IRS revenue procedure governing revocations.

Ruling snapshot

  • Question: What happened to the taxpayer's earlier communications excise tax ruling?
  • Outcome: Revocation of LTR 8529094, effective October 1, 2001.
  • Key authorities: IRC §§ 4251, 4253(f); Rev. Proc. 2001-1, § 12.04.

Full text (IRS public release)

INTERNAL REVENUE SERVICE

Number: 200149012
Release Date: 12/7/2001
Index Nos.: 4252.00-00
4253.06-00

CC:PSI:8/PLR-143447-01

August 27, 2001
In re:

Legend:

Dear
:

On April 25, 1985, the IRS issued a letter ruling, LTR 8529094, to Taxpayer concerning whether certain communications services are exempt from the excise tax imposed by § 4251 of the Internal Revenue Code by reason of § 4253(f).

In accordance with section 12.04 of Rev. Proc. 2001-1, 2001-1 I.R.B. 1, 46, the IRS is revoking LTR 8529094. The effective date of the revocation is October 1, 2001.
Section 6110(k)(3) provides that this document may not be used or cited as precedent.

Sincerely,
Associate Chief Counsel
(Passthroughs and Special Industries)
By: Ruth Hoffman
Senior Technician Reviewer, Branch 8

Enclosures (2):

Copy of this letter
Copy for § 6110 purposes

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