IRS Letter Ruling
201234034 ("Taxpayer A has not presented any evidence .
Although, as illustrated by the last example, the recipient taxpayer of a private letter ruling
may rely on it, other taxpayers cannot.
In some circumstances, "it will be advantageous to both the (TRS) and the taxpayer to hold a conference before the taxpayer submits the letter ruling
request," and the process and requirements for requesting such a conference are set out in Revenue Procedure 2010-1.
In Letter Ruling
201027015, the taxpayer provided a sample written acknowledgment with the charity's name and address, along with the date of the letter in the letterhead:
In general, the effects of a letter ruling
issued under Rev.
71) Letter Ruling
200548021 (72) addressed the treatment of an S corporation that converted to an LLC, but checked the box to maintain its corporate status; it held that this would be treated as an F reorganization.
200406054 (inclement weather barred taxpayer from making rollover until after 60-day period).
115 (stock interest to attract new president), and Letter Ruling
In Letter Ruling
200625009, a company and a co-owner had acquired a property and operated it as tenants in common.
This letter ruling
, however, contains a hopeful sign that at least a portion of design costs may be eligible for a current deduction as software development.
Notwithstanding the lack of precedential value of private letter rulings
, some revenue agents have asserted that the reasoning in Private Letter Ruling
9426004 supports the capitalization of relocation costs incurred as part of a company-wide restructuring.
2003-43, (3) which grants S corporations, qualified subchapter S subsidiaries (QSubs), ESBTs and QSSTs a 24-month extension to file Form 2553, Election by a Small Business Corporation, Form 8869, Qualified Subchapter S Subsidiary Election, or a trust election, without obtaining a letter ruling