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LLP FAQ
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Revenue Rulings are second to Regulations as important administrative sources of the federal tax law. A Revenue Ruling is an official pronouncement of the IRS dealing with the application of the IRC and Regulations to a specific factual situation, usually one that has been submitted by a taxpayer.
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The most impactful and binding types of authority are called primary sources. These primary sources are tax law authorities that must be followed and include: the Internal Revenue Code, U.S. Treasury Regulations, Revenue Rulings, and Revenue Procedures.
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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. Any taxpayer whose circumstances are substantially the same as those described in the ruling can rely upon it.
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A revenue ruling is a public decree issued by the Internal Revenue Service (IRS) that essentially has the force of law. A revenue ruling outlines the IRS's interpretation of the tax laws and is binding on all IRS employees and public taxpayers.
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A Revenue Ruling is an official pronouncement of the National Office of the IRS that deals with the application of the Code and Regulations to a specific factual situation, usually one that has been submitted by a taxpayer. Thus, many Revenue Rulings indicate how the IRS will treat a given taxpayer transaction.
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(e) Taxpayers generally may rely upon Revenue Rulings published in the Bulletin in determining the tax treatment of their own transactions and need not request specific rulings applying the principles of a published Revenue Ruling to the facts of their particular cases.
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Notwithstanding the non-precedential nature of informal guidance like forms instructions, publications and IRS.gov webpages, a taxpayer's reasonable reliance on that informal guidance (even if the informal guidance is subsequently updated or modified) is relevant and will be considered in determining whether certain ...
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Revenue Rulings A revenue ruling is a pronouncement on a specific factual situation that has been submitted by a taxpayer, published for the guidance of all taxpayers. It doesn't carry the force and effect of a regulation but can be cited as precedent by taxpayers with similar situations.
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