The IRS publicly released a private letter ruling concluding that a rural telephone cooperative’s gain realized on the sale of cellular-phone non-utilized spectrum, originally purchased to meet existing patrons’ service demands and for potential expansion of cellular-phone service to new patrons, qualified as patronage-sourced income. PLR 201515012 (release date April 10, 2015; dated December 16, 2014.
Read PLR 201515012 [PDF 56 KB]
The IRS previously reached a similar conclusion in a private letter ruling publicly released in early 2015. Read PLR 201507004 [PDF 63 KB] (sale of cellular-phone spectrum, originally purchased for purpose of expanding services to patrons, qualifies as patronage-sourced income).
For more information, contact KPMG’s National Director of Cooperative Tax Services:
David Antoni | +1 (267) 256-1627 | firstname.lastname@example.org
Or Associate National Director of KPMG’s Cooperative Tax Services
Brett Huston | +1 (916) 554-1654 | email@example.com
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