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.


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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 |

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