2003-16, which provided for automatic waivers of the 60-day requirement and waivers in private letter rulings
, did not discuss the grant of waivers during IRS examinations.
In those instances, particularly if adverse tax consequences could result in a significant tax liability, the taxpayer should consider requesting a private letter ruling
from the Internal Revenue Service.
A cursory review of established judicial doctrine shows support for several key restrictions on the use of private letter rulings
. In the footnotes to a 1984 case, the U.S.
The first issue addressed in the letter ruling
relates to whether the credit card rebates are includible in the gross income of the taxpayer (credit card customer).
98-1 also provides a sample format for a letter ruling
request complete with the proper mailing address.
(34) IRS Letter Rulings
200637008 (9/15/06); 200616023 (4/21/06); 2001614020, 200614021 and 200614022 (all dated 4/7/06); 200615019 (4/14/06); and 200606004 (2/10/06).
* Letter ruling
200402029 (taxpayer's physical incapacity prevented compliance with rollover requirements).
Nevertheless, practitioners may have believed that public companies would be loathe to employ any distribution mechanism involving the word "liquidation." The corporation in Letter Ruling
(77) IRS Letter Rulings
200604016 (1/27/06) and 200622038 (6/2/06).
Treasury regulations issued under section 6662 provide that both private letter rulings
and GCMs are substantial authority, reversing the position under the old regulations cited by the court.
96-30 as a whole, i.e., how to request a private letter ruling
under its various provisions.
200625009, 20051-3010 and 200327003 all held that an undivided fractional interest was not a partnership.