What are Revenue Rulings?
Revenue Rulings are officially published by the IRS.
They may be fact-specific, but they are directed to all taxpayers.
"Revenue Rulings (Rev. Rul.) represent the conclusions of the Service on the application of the law to specific facts stated in the ruling. In rulings based on positions taken in private letter rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements" (IRM 220.127.116.11.6).
Many Revenue Rulings are similar to Private Letter Rulings, but the IRS has determined that the matter is of general interest and should be published as a Revenue Ruling in the Internal Revenue Bulletin. They may also be used in situations where the IRS desires to respond to a particular case or decision.
Numbering and Format:
Revenue rulings are numbered consecutively each year (i.e. Rev. Rul. 2013-22). They follow a similar format, including sections on Issue, Facts, Law and Analysis, Holding, and Effect on Other Rulings.
Revenue rulings, while not as authoritative as regulations, can be relied upon by taxpayers in circumstances similar to the facts presented in the ruling.
Revenue rulings may constitute substantial authority for avoiding the substantial understatement penalty.
How Do I Access Revenue Rulings?
- Via the Internal Revenue Bulletins available from IRS.gov
Electronic to Authorized Users:
- Via WestlawNext
- Via Bloomberg Law
- (From the Tax Practice Center, choose Regulatory Agencies and then Revenue Rulings)
- Via RIA Checkpoint
- (From the main page, under Primary Source Materials, click the + next to IRS Rulings and Releases, and then choose Revenue Rulings)
- Via the Bloomberg/BNA Tax and Accounting Center
- Via LexisNexis Academic
- Via CCH Intelliconnect