revenue ruling


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Related to revenue ruling: Letter Rulings

Ruling

An official opinion by the IRS on how it interprets U.S. tax law. The IRS may make a ruling, for example, after seeing taxpayers apply a deduction or credit to an unusual, but still relevant situation. The IRS determines whether or not it will accept the situation, and, afterward, applies the ruling to all comparable situations. It is also called a revenue ruling, a letter ruling, or a private letter ruling.

revenue ruling

The written guidance that is provided taxpayers by the Internal Revenue Service. Although revenue rulings apply to individual situations, they are often of general interest because of the manner in which the IRS interprets a particular tax problem. Also called letter ruling, ruling.

revenue ruling

Advice from the IRS national office regarding application of the law to a particular fact situation on which a taxpayer has requested guidance.Any taxpayer may rely on a revenue ruling as guidance for similar conduct,but courts are not bound by them if a court thinks the IRS was wrong.Contrast with private letter rulings (also called letter rulings) which issue from a local IRS office and which can be relied upon only by the taxpayer to whom the letter was addressed. Contrast also with a technical advice memorandum issued under different rules but still binding on the IRS only as regards one particular taxpayer.

References in periodicals archive ?
On August 14, 2000, Tax Executives Institute filed the following brief with the Supreme Court of the United States concerning the deference to be accorded revenue rulings issued by the Internal Revenue Service.
A careful reading of Revenue Ruling 94-38 indicates the three factor test was applied by comparing the value, life, and use of the property after the cleanup to when it was acquired by the taxpayer.
The ruling specifically distinguishes Revenue Ruling 77-17, which held that losses sustained in the open market resulting from fraudulent activity of a corporation's officers or directors are capital in nature.
Third, the IRS should "scrub" the Cumulative Bulletin to remove all revenue rulings and other published guidance inconsistent with the final regulations or that no longer reflect the views of the IRS.
Along with the revenue procedure, the IRS issued Revenue Ruling 2002-35, which clarifies that payments to employees for equipment they are required to provide as a condition of employment are wages for federal employment tax purposes, unless such payments are paid under an accountable plan.
The IRS has also been in the process of issuing revenue rulings in the health care area that deal with, among other things, not-for-profit status and maintaining that status.
A revenue ruling is an official interpretations by the IRS of the internal revenue laws, statues, and regulations and sets forth the conclusions of the IRS on how tax is applied to an entire set of facts.
While a revenue ruling is a pronouncement of the agency of the government charged with interpreting and enforcing the tax laws, courts have frequently held that an IRS ruling is merely the opinion of an attorney or group of attorneys who work for one party to the controversy.
However, Revenue Ruling 55-431 states that "as a general rule, an individual who accepts an occasional invitation to make a speech .
Although Correll elevates longstanding rulings that have Congressional approval to some type of legal status on par with statutes, the average revenue ruling does not fall into that category.
In a surprising decision, Revenue Ruling 2004-18 has "clarified" Revenue Ruling 94-38 and Revenue Ruling 98-25 by specifying that previously deductible environmental cleanup costs must be capitalized as indirect costs of inventory in accordance with IRC section 263A.
Moreover, even if the IRS were to challenge the employer's reliance on its outdated rulings, it will likely be precluded from arguing against the public guidance articulated in an outstanding revenue ruling.