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- Revenue Procedure 1999-1 - Letter Rulings, Determination Letters, And Information Letters. Issued
Get Revenue Procedure 1999-1 - Letter Rulings, Determination Letters, And Information Letters. Issued
IS THE PURPOSE OF THIS REVENUE PROCEDURE? SECTION 2. IN WHAT FORM IS GUIDANCE PROVIDED BY THE OFFICES OF ASSOCIATE CHIEF COUNSEL (DOMESTIC), ASSOCIATE CHIEF COUNSEL (EMPLOYEE BENEFITS AND EXEMPT ORGANIZATIONS), ASSOCIATE CHIEF COUNSEL (ENFORCEMENT LITIGATION), AND ASSOCIATE CHIEF COUNSEL (INTERNATIONAL)? p. 12 p. 12 .01 Letter ruling .02 Closing agreement .03 Determination letter .04 Information letter .05 Revenue ruling .06 Oral guidance (1) No oral rulings, and no written rulings in response.
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Spinoffs FAQ
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Effect of Section 6110 on Letter Rulings Subject to the deletion of certain information, letter rulings are required to be open to public inspection under section 6110.
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Letter Rulings are similar to Revenue Rulings, but they are relied upon as precedent only by the taxpayer to whom the ruling is issued. The name and other identifying information concerning the taxpayer requesting the P.L.R. is redacted. Private Letter Rulings are not officially published in a reporter.
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A determination letter is similar in purpose and nature to a private letter ruling, except that it is issued by the office of the local IRS district director not the national office of the IRS.
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Where fast-track handling is available, the IRS will endeavor to issue a private letter ruling in a compressed time frame, generally about 12 weeks. Outside of the fast-track process, the IRS generally aims to respond to ruling requests within 180 days of receipt, though more complex issues can take more time.
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While a revenue ruling generally states an IRS position, a revenue procedure provides return filing or other instructions concerning an IRS position.
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A private letter ruling, or PLR, is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayer's represented set of facts. A PLR is issued in response to a written request submitted by a taxpayer. A PLR may not be relied on as precedent by other taxpayers or by IRS personnel.
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Revenue rulings are published in the Internal Revenue Bulletin & Cumulative Internal Revenue Bulletin.
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Letter Rulings are similar to Revenue Rulings, but they are relied upon as precedent only by the taxpayer to whom the ruling is issued. The name and other identifying information concerning the taxpayer requesting the P.L.R. is redacted. Private Letter Rulings are not officially published in a reporter.
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