The Office of the IRS Chief Counsel released an advice memorandum*—program manager technical assistance (PMTA)—addressing whether or when the federal excise tax under section 4261 applies for prepaid gift cards redeemable for travel on commercial airlines or for “jet cards” offering a fixed price for flying time on aircraft. PMTA-2015-01 (March 11, 2015)
PMTA-2015-01 [PDF 114 KB] concludes that:
*Legal advice memos, issued to program managers, are signed by attorneys in the National Office of the Office of Chief Counsel and issued to IRS personnel who are national program executives and managers. The memos are issued to assist IRS personnel in administering their programs by providing authoritative legal opinions on certain matters, such as industry-wide issues. The memos cannot be used or cited as precedent.
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