The IRS issues private letter rulings in response to a taxpayer's request for the IRS's position on a specified tax issue. The taxpayer asks the IRS for their interpretation of the IRC, regulations, and pertinent court cases for a specific transaction the taxpayer describes. Private letter rulings typically deal with proposed transactions.
NOTE: Letter rulings can only be cited as precedence by the person requesting the ruling, and in no way binds the IRS to take a similar position when dealing with a different taxpayer.
However, letter rulings are an important source of information since they indicate how the IRS may treat a similar transaction. The IRS does not publish its reply in the Internal Revenue Bulletin or Cumulative Bulletin, instead it sends its response only to the taxpayer who submitted the request. Common abbreviations the you may encounter for private letter rulings are PLR and LTR, both indicate the same item. | More Information |
| Title |
Citation |
| Returns Requiring Payment of Interest |
LTR 9104012 |
| Special Use Valuation of Mixed Use Property Must Derive From Multiple Factor Method |
LTR9328004 |
| Information Reporting Requirements |
LTR 9544005 |
| Information Reporting Requirements Under Sections 6041 and 6050N |
LTR 9643004 |
| S Corporation Qualifies For Relief From Built-In Gains Tax |
LTR 9739046 |
| Like-Kind Exchange of Foundation Property is Not Self Dealing |
LTR 9739033 |
| Proposed Trust is Qualified Personal Residence Trust. |
LTR 9735035 |
| S Corporation Qualifies For Relief From Built-in Gains Tax. |
LTR 9732030 |
| S Corporation Qualifies For Relief From Built-in Gains Tax. |
LTR 9729017 |
| Trust Will Retain Exempt Status After Partition and Modifications. |
LTR 9728043 |
| Timber Not Subject to Built-In Gains Tax |
LTR 9726015 |
| S Corporation Qualifies For Relief From Built-in Gains Tax. |
LTR 9719032 |
| Trust Funded With Unproductive Property Not Eligible For QTIP Treatment. |
LTR 9717005 |
| S Corporation Qualifies For Relief From Built-in Gains Tax. |
LTR 9712028 |
| S Corporation Qualifies For Relief From Built-in Gains Tax. |
LTR 9712027 |
| Receivables Marked to Market |
LTR 9836002 |
| Trust Will Be Qualified Personal Residence Trust |
LTR 9827037 |
| Group's Restructuring Is Tax-Free |
LTR 9827020 |
| Timber Not Subject to Built-In Gains Tax |
LTR 9826016 |
| Timber Not Subject to Built-In Gains Tax |
LTR 9826017 |
| Timber Not Subject to Built-In Gains Tax |
LTR 9825018 |
| Coal Royalties Not Passive Investment Income |
LTR 9825008 |
| Income From Sale of Engineered Wood Products Is 'Qualifying Income' |
LTR 9822034 |
| Income From Sale of Wood Products Is 'Qualifying Income' |
LTR 9822035 |
| Timber Contract Satisfies Gain or Loss Provisions |
LTR 9822020 |
| Nursery May Deduct Cost of Trees |
LTR 9818006 |
| Trust Will Be Qualified Personal Residence Trust |
LTR 9817004 |
| Amounts Realized by Foundation Under Timber Contract Are Not UBTI |
LTR 9815056 |
| Timber Income Not Subject to Built-in Gains Tax |
LTR 9802005 |
| Timber Not Subject to Built-In Gains Tax |
LTR 9911035 |
| Contract Modification Is Involuntary Conversion |
LTR 9911048 |
| REIT's Income From Timber Is Treated as Derived From Real Property |
LTR 9925015 |
| Exchange Qualifies as Like-Kind |
LTR 9926045 |
| REIT's Income From Timber Is Treated as Derived From Real Property |
LTR 9927021 |
| Fig Tree Growers Subject to Uniform Capitalization Rules |
LTR 9929001 |
| Exercise of Option Will Not Be Self-Dealing |
LTR 9930048 |
| Partnership Gains Treated as Qualifying Income |
LTR 9932024 |
| Partition of Trusts Won't Affect GSTT Exemption |
LTR 9933027 |
| REIT's Income From Timber Is Treated as Derived From Real Property |
LTR 9945055 |
| Grape Vine Growers Subject to Capitalization under Section 263A |
LTR 9946003 |
| Exemption from tax on corporations, certain trusts, etc. (Exempt v. not exempt) |
LTR 0041038 |