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IRC Section 7871 - TAM


Technical Advice Memorandum - IRC Section 7871
Issue TAM Number
Whether the construction and operation of a project by the Tribe is an exercise of an essential and governmental function within the meaning of Section 7871(e).

TAM 200704019


Whether Tribe can be treated as a governmental unit for purposes of section 103(a) regardless of whether the proceeds of the Bonds are used to exercise an essential governmental function.



Whether: 1) X may purchase gasoline and/or diesel fuel tax free for resale through its service stations to members of its tribe and the general public.  2) After October 13, 1987, X's tribal economic subsidiaries are considered to be engaged in 'essential governmental functions' and are permitted to purchase gasoline and/or diesel fuel tax free for use in their operations. 



Page Last Reviewed or Updated: 10-Apr-2017