Ezel / IRS Rulings / 9933015

PLR 9933015: IRS revokes earlier audio conferencing tax ruling

Number
9933015
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 1994 ruling to a taxpayer about whether section 4251 communications tax applied to certain audio conferencing services. This letter revokes that earlier ruling, LTR 9507013, effective August 1, 1999. It cites the ruling procedure for the revocation and its effective date but does not explain the underlying tax treatment or the reason for the change.

Ruling snapshot

  • Question: Would the IRS leave its earlier section 4251 ruling 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: 199933015
Release Date: 8/20/1999

CC:DOM:PS&I:8/PLR-101888-99

5-12-1999

In re:

Legend:

Dear

On November 14, 1994, the Internal Revenue Service issued a letter ruling, LTR 9507013, 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 9507013. 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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