letter ruling


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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.

letter ruling

letter ruling

A written statement from the IRS to a particular taxpayer, containing an interpretation of tax law as it applies to that taxpayer's situation. Letter rulings are issued in response to a request from a taxpayer and are not binding on the IRS as it relates to other cases.

References in periodicals archive ?
Letter Ruling 200222026 provides that if a partnership has an outstanding partner loan on the termination date, the termination causes the debtor-creditor relationship to be merged and, as a result, the debt is extinguished.
The answer depends upon whether poison pill rights constitute "other property." In light of the IRS's rulings before Letter Ruling No.
Only the national office can revoke a letter ruling (typically because of statutory, judicial or administrative changes in the tax law).
(4) IRS Letter Rulings 200522009 (6/3/05) and 200443018 (10/22/04).
Recently, Letter Rulings 200518012 and 200519042 held that disclaimers were qualified, despite the fact that the disclaimant maintained a role with respect to private foundations that received the disclaimed property.
Nevertheless, the IRS has approved of such plans; see Letter Ruling 9237013, in which the IRS reasoned that the base capital plan was consistent with subordination of capital, using the following analysis:
(15) See, e.g., IRS Letter Rulings 200443031 (10/22/04); 200431009 (7/30/04); 200426014 (6/25/04) and 200413004 (3/26/04).
2002-20, 2002-1 CB 794; see also IRS Letter Ruling 9903001 (1/25/99).
(57) IRS Letter Ruling 200346016 (11/14/03) and 200347012 (11/21/03).
In Letter Ruling 200422020, two existing long-time activities were doing business as an S corporation and its QSub.
Under the procedure, the taxpayer applies for a hardship exception waiver via a letter ruling, as outlined in Rev.
The trustees often advise the taxpayer to obtain a private letter ruling that waives the 60-day requirement.