30:(IRS) in response to taxpayer requests for guidance. A letter ruling is "a written statement issued to a taxpayer by an Associate Chief Counsel Office of the Office of Chief Counsel or by the Tax Exempt and Government Entities Division that interprets and applies the tax laws to a specific set of facts."
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A letter ruling binds both the IRS and the requesting taxpayer (in the event the matter is further disputed or litigated) but only those parties, so the ruling may not be relied on as precedent by other taxpayers. The IRS has the option, however, of redacting the personal content of a letter ruling
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The request for advice must concern the interpretation and application of the internal revenue laws, tax treaties, regulations, revenue rulings, or other precedents to a specific set of facts to determine the correct tax treatment for an item in a year under audit or on appeal.
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during the course of an IRS examination. A TAM is generally issued by an IRS Associate Chief
Counsel Office to an IRS Division Commissioner, or to an IRS Appeals Area Director. A TAM is issued after a request for assistance arising during "any proceeding" before the IRS.
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Mitchell
Rogovin & Donald L. Korb, "The Four R’s Revisited: Regulations, Rulings, Reliance, and Retroactivity in the 21st Century: A View From Within", 46 Duquesne Law Review 323, 342 (2008).
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Mitchell
Rogovin & Donald L. Korb, "The Four R’s Revisited: Regulations, Rulings, Reliance, and Retroactivity in the 21st Century: A View From Within", 46
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A technical advice memorandum (TAM) is similar to a letter ruling, but is typically
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A description of procedures and current guidance is found at the IRS web page
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to the public through the IRS Electronic reading room (see
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26:), in the United States, are written decisions by the
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99:How would I obtain a private letter ruling?
56:Similarity to technical advice memorandum
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42:PLRs from 1997 onwards are available
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34:and issuing that content as a
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140:Taxation in the United States
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150:Internal Revenue Service
28:Internal Revenue Service
20:Private letter rulings
145:United States tax law
16:US taxpayer guidance
121:Duquesne Law Review
79:Advance tax ruling
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155:Tax terms
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