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Determination Letters and Letter Rulings

Determination Letters:

  • IRS and taxpayer agree on treatment of completed transaction prior to return filing
  • Applies principles and precedents previously announced to a specific set of facts
  • Taxpayer requests determination in writing; subject to a user fee
  • Inspection or review of books and records prior to filing is not considered an audit
  • Not concluded with a Closing Agreement so there is less finality
  • Not reviewed by National Office Chief Counsel
  • Decisions made public without identifying information
  • Determination Letter attached to return when filed

Letter Rulings:

  • Taxpayer requests written statement issued from National Office Chief Counsel that applies the tax laws to the taxpayer’s specific set of facts
  • Request is subject to a user fee
  • Issued on proposed or completed transaction prior to the filing of the return and identical issue not on earlier return that was examined, in Appeals, or in litigation
  • Decisions made public without identifying information
  • Letter Ruling attached to return when filed

The Service ordinarily will not issue letter rulings or determination letters in certain areas because of the factual nature of the problem involved or because of other reasons. For further information, see Revenue Procedures:

Revenue Procedure 2014-1
Revenue Procedure 2014-3 and
Revenue Procedure 2014-7.

Page Last Reviewed or Updated: 03-Feb-2014