letter ruling

Private letter ruling

Private letter rulings are written decisions by the Internal Revenue Service in response to taxpayer requests for guidance. A private letter ruling binds only the IRS and the requesting taxpayer. Thus, a private ruling may not be cited or relied upon for precedent. The IRS does have the option of redacting the text of a private ruling and issuing it as a revenue ruling, which become binding on all taxpayers and the IRS. Some private letter rulings are published as a public Revenue ruling; however, most are only available to the public through IRS disclosure procedures. (see ).

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