The national office of the IRS issues private letter rulings in response to a taxpayer's request for the IRS's position on a specified tax issue. The taxpayer asks the IRS for their interpretation of the IRC, regulations, and pertinent court cases for a specific transaction the taxpayer describes. Private letter rulings typically deal with proposed transactions.
NOTE: Letter rulings can only be cited as precedence by the person requesting the ruling, and in no way binds the IRS to take a similar position when dealing with a different taxpayer.
However, letter rulings are an important source of information since they indicate how the IRS may treat a similar transaction. The IRS does not publish its reply in the Internal Revenue Bulletin or Cumulative Bulletin, instead it sends its response only to the taxpayer who submitted the request. Common abbreviations the you may encounter for private letter rulings are PLR and LTR, both indicate the same item. | More Information |
Subject - To search for a Letter Ruling by subject matter click on a subject heading below or refer to the Master Index.
Full List - For a complete list of relevant Letter Rulings click here.
This is not an exhaustive list of all the relevant letter rulings. We started with the most recent rulings and will continue to work back in time. If you do not find what you are looking for please try the IRS website, or check back later.