Federal Tax Research: Letter Rulings

"A 'letter ruling' , also known as a 'private letter ruling' , is a written determination issued to a taxpayer by an associate chief counsel office in response to the taxpayer's written inquiry, filed prior to the filing of returns or reports that are required by the tax laws, about its status for tax purposes or the tax effects of its acts or transactions." (Letter Rulings, IRM § 4.8.8.12.2.3)

"A private letter ruling, or PLR, is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayer's specific set of facts . . . A PLR is issued in response to a written request submitted by a taxpayer . . ." (IRS Website)

Letter rulings are not published in the Internal Revenue Bulletin.

The following citation resources may be informative.

• Bluebook R. 14, Administrative and Executive Materials

• Bluebook T1.2, Federal Administrative & Executive Materials ("Private Letter Rulings: Cite by number and the date issued, if available. > I.R.S. Priv. Ltr. Rul. 86-01-012 (Sept. 30, 1985) . . .")

• IRM § 4.10.7.2.10.2, Citing PLRs and TAMs ("Letter rulings and technical advice memorandums are cited PLR or TAM, respectively, followed by a seven digit number. For example, PLR 8210019 or TAM 9643001. The first two digits indicate the year the ruling was published, for example, 1982 and 1996, respectively . . .")

• TaxCite, Pt. 1, C. 3c, Private Letter Rulings and Technical Advice Memoranda

Below are links to select sources offering private letter rulings.

Below is a pertinent abbreviation.

• Private Letter Ruling=Priv. Ltr. Rul. or PLR
• Letter Ruling=Ltr. Rul. or LTR