Letter Rulings

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Define: Letter Rulings

A private letter ruling (PLR or Ltr. Rul.) is a written statement issued by the IRS to a taxpayer that interprets and applies tax laws to the taxpayer’s specific set of facts. It is issued to establish with certainty the federal tax consequences of a particular transaction before the transaction is consummated or before the taxpayer’s return is filed. It is issued in response to a written request submitted by a taxpayer and is binding on the IRS if the taxpayer fully and accurately described the proposed transaction in the request and carries out the transaction as described. A private letter ruling may not be relied on as precedent by other taxpayers or IRS personnel. Private letter rulings are generally made public after all information has been redacted that could identify the taxpayer to whom it was issued.