Get Regulation GL 1-96 - Authority To Modify Or Rescind Taxpayer ...

Substantial Authority means the weight of authorities for the tax treatment of an item is substantial in relation to the weight of authorities supporting contrary positions.

(1) The Code, Treasury Regulations and published revenue rulings state the position of the Service and are the prime authority for Service personnel. (2) Court decisions are some authority. Generally, the higher the court, the greater the weight of the precedent.

A letter ruling binds only the IRS and the requesting taxpayer, so it may not be cited or relied on for precedent. The IRS does have the option of redacting the text of a private ruling and issuing it as a revenue ruling, which may become binding on all taxpayers and the IRS.

A tax position refers to a decision taken by a taxpayer regarding the treatment of a specific item or transaction on their tax returns.

They also provide insight to taxpayers and researchers on tax issues. Guidance documents with substantial authority include the following categories: A Revenue Ruling (Rev. Rul.) is an official IRS interpretation of tax law (the Code, related statutes, treaties, or regulations) with respect to a specific set of facts.

Revenue rulings are used by taxpayers and tax professionals as reliable guidelines for their own returns or the returns of their clients. Revenue rulings and procedures in the Bulletins don't have the force and effect of Treasury Department Regulations but are able to be used as precedents.