Private letter ruling
Encyclopedia
Private letter rulings in the United States, are written decisions by the Internal Revenue Service
(IRS) 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 as precedent. The IRS does have the option of redacting the text of a private ruling and issuing it as a revenue ruling, which becomes binding on all taxpayers and the IRS. Some private letter rulings are ultimately published as a public Revenue ruling
and become binding on the IRS for all taxpayers. PLRs are available to the public through the IRS Electronic reading room. (see ).
Internal Revenue Service
The Internal Revenue Service is the revenue service of the United States federal government. The agency is a bureau of the Department of the Treasury, and is under the immediate direction of the Commissioner of Internal Revenue...
(IRS) 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 as precedent. The IRS does have the option of redacting the text of a private ruling and issuing it as a revenue ruling, which becomes binding on all taxpayers and the IRS. Some private letter rulings are ultimately published as a public Revenue ruling
Revenue Ruling
Revenue Rulings are public administrative rulings by the Internal Revenue Service of the United States federal government that apply the law to particular factual situations. A revenue ruling can be relied upon as precedent by all taxpayers....
and become binding on the IRS for all taxpayers. PLRs are available to the public through the IRS Electronic reading room. (see ).