PLRs: Cooperative’s sale of cellular-phone spectrum, patronage-sourced income

Cooperative’s sale of cellular-phone spectrum

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.

Related content

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 |


Or Associate National Director of KPMG’s Cooperative Tax Services

Brett Huston | +1 (916) 554-1654 |

© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal



KPMG's new digital platform

KPMG's new digital platform