Determination Letters are similar to private letter rulings, except that they are produced by the IRS district offices rather than the national office. Determination Letters are issued in response to taxpayer requests involving completed transactions and have the same force and effect as Private Letter Rulings. Determination Letters apply to a particular set of facts and are issued only when a determination can be made on the basis of clearly established rules as set forth in the tax law statutes or Treasury Regulations, or by rulings, opinions or court decisions published in the IRB.
Although determination letters can be requested by individuals, they are usually used by institutions, both commercial and non-profit.
IRS Determination Letters are not available on Lexis Advance or Westlaw.