Services (Rev. Rul. 71-21)

ID: CCA_2010121615424052 Number: 201103052
Release Date: 1/21/2011
Office: ---
UILC: 451.13-01
From: ---
Sent: Thursday, December 16, 2010 3:42:40 PM
To: ---
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Cc:
Subject: Rev. Proc. 2004-34 deferral
In administering Rev. Proc. 2004-34, we interpret section 4.01(3)(d) to apply both to hotel rooms used for overnight stays and to special-function rooms, such as banquet halls. In either case, the use of the property is ancillary to the services provided (such as housekeeping). Section 3.08 of Rev. Proc. 71-21 treated advance payments for hotel rooms similarly.