obÌåÓý

The Work SOI Does

2015 Document 6209, Appendix

ANNOUNCEMENT 2003-43 - PFA

Competent Authority Arrangement Between the Competent Authorities of the United States of America and the Republic of Honduras

Resolution of IRC section 461(f) Contested Liability Tax Shelter Issues

This GCM revokes GCM 35,151,1-4848 (December 7, 1972), which held that a person paying an amount subject to the IRC ¡ì 4251 telephone excise tax that refuses to pay tax is subject to the addition to tax under IRC ¡ì 6651(a)(3). The analysis and holding of the prior GCM are inconsistent with IRC ¡ì 6501(b)(4).