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 ?
The organization explained that the Federal Circuit looked to the deference to be accorded IRS revenue rulings because the parallels between IRS and Customs rulings convinced it that "the latter, like the former, do not require Chevron deference.
The government also elliptically quotes a law review article to buttress its contention that "following" Correll, "circuit courts have uniformly held that Revenue Rulings receive significant deference.
The reasoning of Revenue Ruling 2000-2 is not new to QTIP trusts: With respect to nonretirement assets, a marital deduction will be allowed if a trust instrument merely gives the surviving spouse the right to the income.
That case involved the deference to be granted interpretative regulations that had been issued as a Treasury Decision (and subject to notice and comment), not a revenue ruling.
The IRS has, however, issued Revenue Ruling 9438 [1994 1 C.
A taxpayer who takes a return position contrary to a notice or revenue ruling must comply with the Sec.
deduction issues through the various guidance mechanisms, including the technical advice procedures and the revenue ruling process.
On November 25, 2002, the Internal Revenue Service released revenue ruling 2002-83 in Internal Revenue Bulletin (IRB) 2002-49.
It was determined that the issue was one of national importance and that the Service's position should be published in a revenue ruling.
The IRS acquiesced to Palmer in revenue ruling 78-197, saying that "the Service will treat the proceeds of a redemption (or sale) of stock .
98-15 is only the second revenue ruling issued by the Service in the health care arena since 1986.