Ezel / IRS Rulings / 200242021

IRS determination 200242021: Earlier communications tax ruling revoked

Number
200242021
Outcome
Revocation
Document type
Determination Letter
IRS subject
Communications Tax (Taxable v. Not Taxable)
Topics
Excise taxes
Code sections
§ 4251
Ruling dated
July 15, 2002
Publicly released
October 18, 2002
Source
View Official PDF

Apply this to your situation

This page covers one taxpayer's determination, 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 revoked an earlier letter ruling about a taxpayer's responsibility for the section 4251 excise tax on payments for communication services. The earlier ruling was LTR 200133008, issued May 24, 2001. This letter says the revocation takes effect August 9, 2002. It does not explain the reason for reconsideration or state a replacement ruling on the tax.

Ruling snapshot

  • Question: What happened to the taxpayer's earlier section 4251 letter ruling?
  • Outcome: Revocation effective August 9, 2002.
  • Key authorities: IRC § 4251; Rev. Proc. 2002-1, § 12.04.

Full text (IRS public release)

INTERNAL REVENUE SERVICE

Number: 200242021
Release Date: 10/18/2002
Index No.: 4251.00-00

CC:PSI:8/PLR-125328-02

In re: July 15, 2002

Legend:

Taxpayer =

Dear
:

On May 24, 2001, the IRS issued a letter ruling, LTR 200133008, to Taxpayer concerning Taxpayer’s responsibility for the excise tax imposed by § 4251 of the Internal Revenue Code on amounts paid for communication services.

Upon reconsideration, in accordance with section 12.04 of Rev. Proc. 2002-1, 2002-1 I.R.B. 1, 50, the IRS is revoking LTR 200133008. The effective date of the revocation is August 9, 2002. 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: Richard A. Kocak
Chief, Branch 8

Enclosures (2):
Copy of this letter
Copy for § 6110 purposes

cc:

What does the Code say today, for your facts?

This determination bound one taxpayer and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace