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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.

Title Citation
Special Use Valuation of Mixed Use Property Must Derive From Multiple Factor Method LTR9328004
S Corporation Qualifies For Relief From Built-In Gains Tax LTR 9739046
Like-Kind Exchange of Foundation Property is Not Self Dealing LTR 9739033
Proposed Trust is Qualified Personal Residence Trust. LTR 9735035
S Corporation Qualifies For Relief From Built-in Gains Tax. LTR 9732030
S Corporation Qualifies For Relief From Built-in Gains Tax. LTR 9729017
Trust Will Retain Exempt Status After Partition and Modifications. LTR 9728043
Timber Not Subject to Built-In Gains Tax LTR 9726015
S Corporation Qualifies For Relief From Built-in Gains Tax. LTR 9719032
Trust Funded With Unproductive Property Not Eligible For QTIP Treatment. LTR 9717005
S Corporation Qualifies For Relief From Built-in Gains Tax. LTR 9712028
S Corporation Qualifies For Relief From Built-in Gains Tax. LTR 9712027
Receivables Marked to Market LTR 9836002
Trust Will Be Qualified Personal Residence Trust LTR 9827037
Group's Restructuring Is Tax-Free LTR 9827020
Timber Not Subject to Built-In Gains Tax LTR 9826016
Timber Not Subject to Built-In Gains Tax LTR 9826017
Timber Not Subject to Built-In Gains Tax LTR 9825018
Coal Royalties Not Passive Investment Income LTR 9825008
Income From Sale of Engineered Wood Products Is 'Qualifying Income' LTR 9822034
Income From Sale of Wood Products Is 'Qualifying Income' LTR 9822035
Timber Contract Satisfies Gain or Loss Provisions LTR 9822020
Nursery May Deduct Cost of Trees LTR 9818006
Trust Will Be Qualified Personal Residence Trust LTR 9817004
Amounts Realized by Foundation Under Timber Contract Are Not UBTI LTR 9815056
Timber Income Not Subject to Built-in Gains Tax LTR 9802005
Timber Not Subject to Built-In Gains Tax LTR 9911035
Contract Modification Is Involuntary Conversion LTR 9911048
REIT's Income From Timber Is Treated as Derived From Real Property LTR 9927021
REIT's Income From Timber Is Treated as Derived From Real Property LTR 9925015
Exchange Qualifies as Like-Kind LTR 9926045
Fig Tree Growers Subject to Uniform Capitalization Rules TAM 9929001
Exercise of Option Will Not Be Self-Dealing LTR 9930048
Partnership Gains Treated as Qualifying Income LTR 9932024
REIT's Income From Timber Is Treated as Derived From Real Property LTR 9945055
Grape Vine Growers Subject to Capitalization under Section 263A LTR 9946003