- Revenue Ruling
Revenue Rulings are public administrative rulings by the
Internal Revenue Service(IRS) that apply the law to particular factual situations. A revenue ruling can be relied upon by all taxpayers.
A taxpayer may, for a fee, seek advice from the IRS as to the proper tax treatment of a transaction. This is called a
private letter ruling. 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.
Revenue rulings are published both in the
Internal Revenue Bulletinand in the Federal Register.The numbering system for revenue rulings corresponds to the year in which they are issued. Thus, for example, Revenue Ruling 79-24 was the twenty-forth revenue ruling issued in 1979.
Public administrative rulings are part of second tier authorities and generally do not prevail over legislative regulations, the Internal Revenue Code, Court Cases and Treaties. However, they hold higher weight than tier 3 authorities such as legislative history and private letter rulings. Revenue Rulings can be used to avoid certain
Revenue rulings are different than revenue procedures. While a revenue ruling is the conclusion of the IRS on how the law is applied to a specific set of facts, a revenue procedure is an official statement of a procedure that affects the rights or duties of taxpayers under the law. Generally, a revenue ruling states the IRS position, whereas a revenue procedure provides return filing or other instructions concerning the IRS position.
For example, a revenue ruling holds that taxpayers may deduct certain automobile expenses, and a revenue procedure provides that taxpayers entitled to deduct these automobile expenses may compute them by applying certain mileage rates in lieu of determining actual operating expenses.
Revenue rulings and revenue procedures are alike in that both are issued only by the National Office and both are for the information and guidance of taxpayers
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revenue ruling — n: an official interpretation of a tax law by the Internal Revenue Service that is published to provide guidance esp. to taxpayers and IRS officials Merriam Webster’s Dictionary of Law. Merriam Webster. 1996. revenue ruling … Law dictionary
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
Revenue Ruling — A decree issued by the IRS that essentially has the force of law. A revenue ruling outlines the IRS s interpretation of the tax laws and is binding on all IRS employees. Revenue rulings are published in the Cumulative Bulletin and are issued only … Investment dictionary
ruling — rul·ing n: an official or authoritative determination, decree, statement, or interpretation (as by a judge on a question of law) followed a previous ruling on the same question see also revenue ruling compare decision, disposition … Law dictionary
ruling — A judicial or administrative interpretation of a provision of a statute, order, regulation, or ordinance; e.g. Revenue Rulings. May also refer to judicial determination of admissibility of evidence, allowance of motion, etc. See also decree order … Black's law dictionary
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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… … Wikipedia
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Internal Revenue Code section 355 — Section 355 of the Internal Revenue Code (IRC § 355) allows a corporation to make a tax free distribution to its shareholders of stock and securities in one or more controlled subsidiaries. If a set of statutory and judicial requirements are met … Wikipedia
letter ruling — n: a ruling (as of a court or administrative agency) that is made in a letter (as an opinion or determination letter); also: determination letter at letter 1 Merriam Webster’s Dictionary of Law. Merriam Webster. 1996 … Law dictionary