Golden Belt Telephone Association, Inc. - Page 7

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          the change is explained by the Senate Finance Committee as                  
          follows:                                                                    
                    The committee believes that the performance by a                  
               telephone cooperative of call-completion services                      
               involving calls to or from members of the cooperative                  
               is substantially related to the cooperative's                          
               performance of its statutory exempt function, and hence                
               that actual or constructive "payments" from another                    
               telephone company for such services should not                         
               disqualify otherwise eligible telephone cooperatives                   
               from tax-exempt status.                                                
                    The committee understands that the approach set                   
               forth in the Service's ruling, described above, might                  
               well make the statutory exemption provision into a                     
               "dead letter," since few, if any, telephone                            
               cooperatives could prove that the constructive                         
               "payments" hypothesized by the Service do not cause the                
               telephone cooperative to fail the 85-percent member-                   
               income test.                                                           
          S. Rept. 95-762 (1978) at 2-3, 1978-2 C.B. 357, 358.  Prior to              
          the 1984 AT&T divestiture, "call-completion services" included              
          B & C services.3                                                            
               In 1986, the FCC issued a decision, In the Matter of                   
          Detariffing of Billing & Collection Servs., 102 FCC2d 1150 (1986)           
          (1986 Detariffing Order), which resulted in the detariffing of              
          B & C services under Title II of the Communications Act of 1934,            
          ch. 652, tit. I, sec. 1, 48 Stat. 1064, 47 U.S.C. sec. 151 et               
          seq. (1937).  In the 1986 Detariffing Order, the FCC concluded              
          that B & C services performed for a non-member long-distance                
          company were not a "communication service", but were instead a              


               3  There is no explanation for the use of the term                     
          "communication services" rather than "call-completion services"             
          in sec. 501(c)(12)(B).                                                      



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