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Glossary/Private letter ruling

What is Private letter ruling?

In short

A private letter ruling is a written statement from the Internal Revenue Service, issued at a taxpayer's request, applying the tax law to that taxpayer's specific facts.

Key takeaways

  • Only the taxpayer who requested it may rely on it.
  • Other taxpayers can't cite it as precedent, though it shows the agency's thinking.
  • Revenue rulings, by contrast, are published and may be relied on by any taxpayer in similar circumstances.

Where it's tested

REG: Internal Revenue Service (IRS) Procedures & Appeals — study notes, a five-minute revision sheet and practice questions.

Practise: 3 questions

Question 1 of 3 · 0 answered

A taxpayer wishes to dispute a proposed deficiency without first paying the disputed amount. Which court must the taxpayer use?

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