• Home
• Federal Income Taxes
• State Tax Laws
• Estate Planning
• Publications
• Professional Research
  • Master Index
  • Case Law
  • Revenue Rulings
  • Private Letter Rulings
  • Regulations
  • Internal Revenue Code
  • Public Laws
  • Research Process
• Tax Workshops/Education
• Tax Policy
• Links

Revenue Rulings

It would be impossible to write regulations covering all possible circumstances, thus other types of rulings and pronouncements are also used in administering and interpreting the Internal Revenue Code. Revenue Rulings are second to Regulations as important administrative sources of the federal tax law. A Revenue Ruling is an official pronouncement of the IRS dealing with the application of the IRC and Regulations to a specific factual situation, usually one that has been submitted by a taxpayer. Most Revenue Rulings indicate how the IRS will treat a given taxpayers transaction and are published primarily for providing guidance to you. The result of a particular ruling can be of great importance if your transaction is similar in nature. Revenue Rulings do not carry the force and effect of a regulation, and caution should be used if the Revenue Ruling has been affected by subsequent legislation, regulations, rulings, or court decisions.

The content of any Revenue Ruling follows the same format, namely:
1. Issue - A statement of the issue in question.
2. Facts - The facts on which the revenue ruling will be based.
3. Law and Analysis - The IRS's application of current law to the issue in the revenue ruling.
4. Holding - How the IRS will treat the transaction

There are hundreds of Revenue Rulings issued each year by the IRS. Each is identified by the year in which it was released ad the number for that year. The IRS publishes them in the weekly Internal Revenue Bulletin and later in the Cumulative Bulletin.

Understanding a Revenue Ruling Citation:

Revenue Rulings are cited as either a temporary or permanent citation.

A temporary citation would look like: Rev. Rul. 95-45, IRB 1995-4, p. 10. where
95 is the year the ruling is issued
45 is the ruling number for that year
IRB is a reference to the Internal Revenue Bulletin
1995-4 is the weekly issue of the IRB
p. 10 is the first page in the IRB that includes the ruling

A permanent citation for the same ruling would look like: Rev. Rul. 95-45, 1995-1 CB 54, where
95 is the year the ruling is issued
45 is the ruling number for that year
1995-1 is the volume number of the Cumulative Bulletin
CB is a reference to the Cumulative Bulletin
54 is the first page in the CB that includes the ruling

Prior to 1953 Revenue Rulings were known by different names including appeals and review memoranda (ARM), general counsel's memorandum (GCM), and office decision (OD). These earlier rulings may still have some application as long as the IRS has not revoked or modified them in any way. The current status of a Revenue Ruling or other IRS ruling can be checked in the most current index of the Cumulative Bulletin.