Private Letter Ruling (PLR)

A written statement issued by the IRS at the request of a taxpayer that interprets and applies the tax laws to a specific set of facts. Reg. §301.6110-2(d). A PLR is not authority and may not be cited. § 6110(k)(3). The first Revenue Procedure issued by the IRS each year describes the procedure to follow in requesting rulings and defines the areas in which rulings will and will not be issued.

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