What are Letter Rulings?
Letter rulings (also referred to as "private letter rulings") are publicly available but are not officially published by the IRS.
They are taxpayer-specific.
A Letter Ruling (LTR), also know as a Private Letter Ruling (PLR), 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" (IRM 18.104.22.168.2.3).
A PLR may not be relied on as precedent by other taxpayers. However, private letter rulings issued after October 31, 1976 may be relied on as substantial authority to avoid the substantial understatement penalty.
Letter rulings have multiple digit file numbers, with the first two digits indicating the year the ruling was issued, the second two digits indicating the week of the year the ruling was released, and the remaining numbers indicating the number of the item issued that particular week (e.g. P.L.R. 99-32-083).
How Do I Access Letter Rulings?
- Via the IRS.gov Electronic Reading Room (scroll down to Non-Precedential Rulings and Advice, then click on IRS Written Determinations)
Electronic to Authorized Users:
- Via Westlaw Next
- Via Bloomberg Law (From the Tax Practice Center, choose Regulatory Agencies and then Private Letter Rulings)
- Via Lexis Advance
- Via RIA Checkpoint
- (From the main page, under Primary Source Materials, click the + next to IRS Rulings and Releases, and then choose Private Letter Rulings and Technical Advice Memoranda)
- Via the Bloomberg/BNA Tax and Accounting Center
- Via LexisNexis Academic
- Via CCH Intelliconnect