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The IRS’s National Office issues Private Letter Rulings, also called “Letter Rulings,” in response to a taxpayer’s request for the IRS’s interpretations of the IRC and regulations regarding a particular situation (usually a prospective transaction). Letter Rulings are not binding on the IRS and cannot be cited as precedent. However, private letter rulings issued after October 31, 1976 may be relied on as substantial authority to avoid the substantial understatement penalty. They are numbered by the year, week and order of issuance (e.g., LTR 923242 indicates the 42nd ruling issued in the 32nd week of 1992).
Listed as IRS Written Determinations. Private Letter Rulings from 1999 - present.
Available on Westlaw from 1950-present.
Available on Lexis Advance from 1954-current.
No Virginia, You Can't Rely On IRS Rulings
2010 article in Forbes by Robert Wood. While a PLR is solely between you and the IRS, by law, PLRs are released to the public with names redacted, and they’ve come to be some of the most important “authority” the IRS produces. The IRS doesn’t release these redacted PLRs out of generosity. Lawsuits were brought by Tax Analysts and Advocates (an Arlington, Virginia nonprofit) to compel their release. You can thank Tax Analysts for breaking loose much of the otherwise secret IRS law, not only PLRs, but also Chief Counsel Advice, Technical Advice Memoranda, Field Service Advice, and many other IRS missives that shed light on what the IRS is doing and thinking.