Determination Letters, Information Letters, Letter Rulings, and Revenue Rulings are written by the IRS as responses to taxpayer questions. The type of letter or ruling delivered depends on the question asked.
Determination Letters answer questions from individual taxpayers regarding tax matters. The answer to the query is covered by the Internal Revenue Code, tax treaties, or caselaw, regulations, and revenue rulings published in the Internal Revenue Bulletin.
"A 'determination letter' is a written determination issued by a Director that applies the principles and precedents previously announced by the Service to a specific set of facts. It is issued only when a determination can be made based on clearly established rules in a statute, a tax treaty, the regulations, a conclusion in a revenue ruling, or an opinion or court decision that represents the position of the Service." Rev. Proc. 2022-1 § 2.03.
For more information about determination letters, check out the first annual revenue procedure, updated each year in the Internal Revenue Bulletin. See I.R.B. 2022-1 for Rev. Proc. 2022-1.
For more information regarding letters and rulings and their authoritative weight, see Tax Management Portfolio 621-4th: IRS National Office Procedures — Rulings, Closing Agreements (also available on the library's Bloomberg Law computers).
See below for how to find letters and rulings.
Determination Letters, Information Letters, Letter Rulings, and Revenue Rulings are written by the IRS as responses to taxpayer questions. The type of letter or ruling delivered depends on the question asked.
Information Letters are written by the IRS National Office in response to requests for general information from taxpayers. They provide general statements of well-defined law without applying them to a specific set of facts.
"An 'information letter' is a statement issued by an Associate office or Director that calls attention to a well-established interpretation or principle of tax law (including a tax treaty) without applying it to a specific set of facts. An information letter may be issued if the taxpayer’s inquiry indicates a need for general information or if the taxpayer’s request does not meet the requirements of this revenue procedure and the Service concludes that general information will help the taxpayer. An information letter is advisory only and has no binding effect on the Service." Rev. Proc. 2022-1 § 2.04.
For more information about information letters, check out the first annual revenue procedure, updated each year in the Internal Revenue Bulletin. See I.R.B. 2022-1 for Rev. Proc. 2022-1.
For more information regarding letters and rulings and their authoritative weight, see Tax Management Portfolio 621-4th: IRS National Office Procedures — Rulings, Closing Agreements (also available on the library's Bloomberg Law computers).
See below for how to find letters and rulings.
Determination Letters, Information Letters, Letter Rulings, and Revenue Rulings are written by the IRS as responses to taxpayer questions. The type of letter or ruling delivered depends on the question asked.
Rulings, also referred to as letter rulings, private letter rulings (PLR), and advance rulings, are statements written by the National Office in response to a specific taxpayer's request for a ruling. They give an opinion on the tax consequences of a specific course of conduct prior to filing a tax return. They are issued only in response to a taxpayer's request for a ruling.
"A ruling is a written statement issued to a taxpayer or his authorized representative by the National Office which interprets and applies the tax laws to a specific set of facts. Rulings are issued only by the National Office. The issuance of rulings is under the general supervision of the Assistant Commissioner (Technical) and has been largely redelegated to the Director, Corporation Tax Division and Director, Individual Tax Division." 26 C.F.R. § 601.201(a)(2) (2020).
"A Private Letter Ruling (PLR) represents the conclusion of the Service for an individual taxpayer. The application of a private letter ruling is confined to the specific case for which it was issued, unless the issue involved was specifically covered by statute, regulations, ruling, opinion, or decision published in the Internal Revenue Bulletin." Internal Revenue Manual 4.10.7.2.10(1) (Jan. 1, 2006).
For more information regarding letters and rulings and their authoritative weight, see Tax Management Portfolio 621-4th: IRS National Office Procedures — Rulings, Closing Agreements (also available on the library's Bloomberg Law computers).
See below for how to find letters and rulings.
Determination Letters, Information Letters, Letter Rulings, and Revenue Rulings are written by the IRS as responses to taxpayer questions. The type of letter or ruling delivered depends on the question asked.
Revenue Rulings are written by the IRS to interpret the tax laws as applied to hypothetical or simplified situations.
"A Revenue Ruling is an official interpretation by the Service that has been published in the Internal Revenue Bulletin. Revenue Rulings are issued only by the National Office and are published for the information and guidance of taxpayers, Internal Revenue Service officials, and others concerned." 26 C.F.R. § 601.601(d)(2)(i)(a) (2020).
For more information regarding letters and rulings and their authoritative weight, see Tax Management Portfolio 621-4th: IRS National Office Procedures — Rulings, Closing Agreements (also available on the library's Bloomberg Law computers).
See below for how to find letters and rulings.
IRS Written Determinations Internal Revenue Service
Coverage begins with 1999.
Internal Revenue Service
Select Revenue Rulings are located throughout the IRS website. To search the IRS website for revenue rulings, use Google's Advance Search and type revenue ruling in the "this exact word or phrase" field and irs.gov in the "site or domain" field. To narrow the search, add other search terms.
Information Letters Internal Revenue Service
Coverage begins with 2000.
IRS Private Rulings and Advice TaxNotes
Filter by 'Letter Rulings & Technical Advice'.
The following member database includes access to IRS Revenue Rulings. Members must be logged in to jenkinslaw.org to access this database. This database is also available in the library.
IRS Revenue Rulings
Available on Fastcase. From Browse Libraries, go to Primary Materials > Administrative Materials > Administrative Opinions > IRS Revenue Rulings. Coverage begins with 1954.
IRS Private Letter Rulings and Technical Advice Memoranda
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Private Letter Rulings and Technical Advice Memoranda. IRS Private Letter Rulings and Technical Advice Memoranda (PLR file) are written determinations issued by the National Office of the Internal Revenue Service that interpret and apply tax law to a taxpayer's specific set of facts. Letter Rulings deal with pre-return filing transactions and are issued directly to individual taxpayers at their request. Coverage begins with 1954.
IRS Exemption Rulings
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Exemption Rulings. Includes documents released by the Internal Revenue Service's Exempt Organizations Technical Division. Coverage from January 1994 (with a few select documents from 1993) through 2015.
IRS Information Letters
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Information Letters. Contains information letters prepared by the national office of the Internal Revenue Service in response to requests for general information by taxpayers and members of Congress. Information letters provide general statements of well-defined law without applying them to a specific set of facts. Coverage begins with 2000.
IRS Private Letter Rulings
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Private Letter Rulings. Contains written determinations issued by the Internal Revenue Service directly to an individual taxpayer in response to the taxpayer's request for an informal opinion regarding a particular transaction or set of facts. Coverage begins with 1950 with selected documents through 1976.
IRS Revenue Rulings
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Revenue Rulings. Contains Revenue Rulings released by IRS that interpret the tax laws as applied to specific factual situations that are selected for publication in the Internal Revenue Bulletin. Coverage begins with 1953, Revenue Ruling #1, 1953-1 CB 36.
Information Letters
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Guidance & Interpretation > Information Letters. An information letter provides general statements of well-defined law without applying them to a specific set of facts. They are furnished by the IRS National Office in response to requests for general information by taxpayers, by congress-persons on behalf of constituents, or by congress-persons on their own behalf. Coverage begins with 2000.
Private Letter Rulings
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Rulings > Private Letter Rulings. Contains informal administrative rulings issued by the IRS related to the tax treatment of certain transactions. Coverage begins with 1977.
Revenue Rulings
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Rulings > Revenue Rulings. Contains administrative rulings issued by the IRS related to the tax treatment of certain transactions. Coverage begins with 1954.
IRS Information Letters
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > IRS Information Letters. IRS Information Letters provide general statements of well-defined law without applying them to a specific set of facts. They are furnished by the IRS National Office in response to requests for general information by taxpayers or by congress. Coverage begins with 2002.
IRS Letter Rulings and TAMS (Current)
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > IRS Letter Rulings and TAMS (Current). Current year only.
IRS Letter Rulings and TAMS (1998-2021)
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Archives > IRS Administrative Rulings & Positions > IRS Letter Rulings and TAMS (1998-2021). Coverage from 1998 through 2021.
IRS Letter Rulings and TAMS (1954-1997)
Available on the library's VitalLaw computer. Tax - Federal > Archives > IRS Administrative Rulings & Positions > IRS Letter Rulings and TAMS (1954-1997). Coverage from 1954 through 1997.
Revenue Rulings
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > Revenue Rulings. Revenue Rulings apply the law to a specific fact situation and can be relied on by a taxpayer and guide the taxpayer in a similar situation. Some Revenue Rulings are primarily directed to the nationwide tax administrative system. Others are issued to clarify various points of interpretation. Revenue Rulings are also used to announce various rates and amounts. Coverage begins with 1954.
IRS Letter Rulings CCH
Library has 1977-1993, 2004-2009. Index coverage, 1977-1999. Indexed by Subject and Code Section. See Transfer Binders. For rulings from 1977-1993, see Microforms.
Revenue Rulings are published in the Internal Revenue Bulletin. Determination Letters, Information Letters, and Letter Rulings are not.
The Internal Revenue Bulletin is available for free online as well as on many legal databases, including the member database HeinOnline and on the library's in house Lexis and Westlaw computers. See the Internal Revenue Bulletin page of this guide for more information.
The Standard Federal Tax Reporter includes Letter Rulings and Revenue Rulings. It does not include Determination Letters or Information Letters.
Jenkins has access to the Standard Federal Tax Reporter on the library's VitalLaw computer beginning with 1986. Pre-1986 coverage is available on the member database HeinOnline. Select coverage is also available in print. See the Standard Federal Tax Reporter page of this guide for more information.