Ezel / IRS Rulings / 9933014

PLR 9933014: IRS revokes 1995 audio conferencing tax ruling

Number
9933014
Outcome
Revocation
Document type
Private Letter Ruling
IRS subject
Communications Tax (Taxable v. Not Taxable)
Topics
Excise taxes
Code sections
§ 4251
Ruling dated
May 12, 1999
Publicly released
August 20, 1999
Source
View Official PDF

Apply this to your situation

This page covers one taxpayer's ruling, issued in 1999, 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 1999
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 a 1995 ruling about whether section 4251 communications tax applied to amounts paid for certain audio conferencing services. This letter revokes that ruling, LTR 9543025, effective August 1, 1999. It cites the ruling procedure governing revocation and the effective date but gives no explanation of the underlying tax treatment or why the earlier ruling was withdrawn.

Ruling snapshot

  • Question: Would the earlier section 4251 ruling remain in effect?
  • Outcome: Revocation, effective August 1, 1999.
  • Key authorities: IRC § 4251; Rev. Proc. 99-1 §§ 12.04, 12.07(2).

Full text (IRS public release)

INTERNAL REVENUE SERVICE
Index No.: 4251.00-00

Number: 199933014
Release Date: 8/20/1999

CC:DOM:PS&I:8/PLR-101889-99

5-12-1999

In re:
Legend:

Dear

On July 27, 1995, the Internal Revenue Service issued a letter ruling, LTR 9543025, to Taxpayer concerning the applicability of § 4251 of the Internal Revenue Code to amounts paid for certain audio conferencing services.

In accordance with § 12.04 of Rev. Proc. 99-1, 1999-1 I.R.B.
6, 47, the Service is revoking LTR 9543025. Consistent with
§ 12.07(2) of Rev. Proc. 99-1, the effective date of the revocation is August 1, 1999. 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:
Bernard H. Weberman
Assistant to the Chief, Branch 8

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

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