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IRS Revokes Prior Advice on Application of Communications Tax Penalty

NOV. 26, 2002

GCM 39892

DATED NOV. 26, 2002
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Citations: GCM 39892

UIL Nos.: 4291.00-00, 6651.00-00, 6501.00-00

 

CC:PRENO-148566-02

 

 

PSI:8:PSKirwan

 

GCM

 

 

Date Numbered: 11/26/2002

 

GCM 35,151, Revocation of

 

 

Heather C. Malloy

 

 

Associate Chief Counsel (Passthroughs and Special Industries)

 

 

Application of Failure to Pay Penalty, GCM 35,151, 1-4848 (December 7, 1972), which held that a person paying an amount subject to the § 4251 telephone excise tax that refuses to pay tax is subject to the addition to tax under § 6651 (a)(3), is revoked. The analysis and holding of the GCM are inconsistent with § 6501(b)(4).
Ruth Hoffman

 

Senior Technician Reviewer,

 

Branch 8

 

Associate Chief Counsel

 

(Passthroughs and Special

 

Industries)
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