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Related to Private Rulings: Private Letter Rulings


A judicial or administrative interpretation of a provision of a statute, order, regulation, or ordinance. The judicial determination of matters before the court such as the admissibility of evidence or the granting of a motion, which is an application for an order.

West's Encyclopedia of American Law, edition 2. Copyright 2008 The Gale Group, Inc. All rights reserved.


n. court decision on a case or any legal question.

Copyright © 1981-2005 by Gerald N. Hill and Kathleen T. Hill. All Right reserved.
References in periodicals archive ?
It is unclear whether the private ruling process could fill these inevitable gaps because of the exclusive nature of the qualifying income list provided in the Proposed Regulations.
It is fundamentally unfair to tax a PTP at the entity level after thoroughly vetting its business and providing a PLR upholding its pass-through tax status, particularly when, as here, the PTP sponsors and investors relied on the private ruling when organizing their respective investments and there is no principled basis in law or fact for revoking the ruling through contrary regulations.
at [paragraph] 5525 (stating that the Lucky Stores court refused to consider the private rulings on section 6110(k)(3) grounds).
6110[(k)](3) on the use or citation of private rulings as precedent" and expressing concern that "such use will have a stultifying effect on the private rulings process").
Indeed, one of the concerns motivating Congress to make these documents public was the fear that this enormous body of tax knowledge and interpretation would result in a secret law, the limited accessibility of which would undermine the private ruling system's credibility.
The precedential effect of private rulings is limited for good reason.
In contrast with private rulings, the legal and policy analyses underlying regulations and revenue rulings are subject to a high level of scrutiny within the IRS (as well as the Treasury Department), which ensures that the articulated position is more likely to be sustained by the courts.
80-76, this private ruling provides that the subsidiary employer (not the parent that actually transferred the property) would receive the deduction.
Other changes made by the revenue procedure are discussed in the second part of this article, relating to obtaining a private ruling letter.
This limitation protects the government from having taxpayer-favorable private rulings cited against its interest by anyone other than the affected taxpayer.
The rationale for limiting the precedential value of private rulings is plain: the review process for private letter rulings is attenuated compared with that for published guidance.

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