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 usc|26|6110).


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  • private — Affecting or belonging to private individuals, as distinct from the public generally. Not official; not clothed with office. People v. Powell, 280 Mich. 699, 274 N.W. 372, 373. As to private act private agent private bill private boundary private …   Black's law dictionary

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  • Revenue Ruling — A Revenue Ruling (abbreviated Rev. Rul. ) is issued by the National Office of the I.R.S. to express an official interpretation of the tax law as applied to specific transactions. Unlike a Regulation, it is more limited in application. A Revenue… …   Black's law dictionary

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