Ezel / IRS Rulings / 200234040

PLR 200234040: IRS revokes two earlier excise tax rulings

Number
200234040
Outcome
Revocation
Document type
Private Letter Ruling
IRS subject
Certain Taxes on Sales and Services
Topics
Procedure, penalties, and administration
Code sections
§ 6416
Ruling dated
May 17, 2002
Publicly released
August 23, 2002
Source
View Official PDF

Apply this to your situation

This page covers one taxpayer's ruling, issued in 2002, 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 2002
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 had issued two rulings to a taxpayer about how IRC § 6416(b)(4)(B) applied to its sales. The second ruling had revoked the first. This letter revokes both earlier rulings, LTR 8910041 and LTR 8819067. It offers no further analysis of the taxpayer's sales or the excise tax consequences.

Ruling snapshot

  • Question: What is the status of the taxpayer's two earlier § 6416 excise tax rulings?
  • Outcome: Revocation of both earlier rulings
  • Key authorities: IRC § 6416(b)(4)(B)

Full text (IRS public release)

INTERNAL REVENUE SERVICE

Number: 200234040
Release Date: 8/23/2002
Index No.: 6416.00-00

CC:PSI:8/PLR-104459-02

May 17, 2002
In re: Letter Rulings Regarding Excise Tax

Legend: Taxpayer =

Dear
:

On February 16, 1988, the IRS issued a letter ruling, LTR 8819067, to Taxpayer concerning the applicability of § 6416(b)(4)(B)(i) of the Internal Revenue Code to Taxpayer’s sales. On December 9, 1988, the IRS issued a letter ruling, LTR 8910041, to Taxpayer concerning the applicability of § 6416(b)(4)(B)(ii) to Taxpayer’s sales and revoking LTR 8819067.

This letter ruling revokes LTR 8910041 and LTR 8819067. 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

cc:

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