Supreme Court considered private letter rulings
to determine how the IRS interpreted the code.
For this reason, each calendar year, in the first issued revenue procedure, the IRS sets forth in great detail the requirements for a private letter ruling
This uncertainty is the reason that quasi-governmental agencies may choose to obtain an opinion letter or private letter ruling
. Nevertheless, contributions or gifts to these entities may still entitle the donor to a charitable contribution deduction subject to certain limitations if the entity is an "instrumentality" of a state or local government (which is a political subdivision of a state).
A private letter ruling
is a procedure that allows a taxpayer to inquire about the tax consequences of a contemplated transaction.
Per Private Letter Ruling
201245004, a surviving spouse who, prior to making a disclaimer, received distributions in excess of the deceased's spouse RMD was ruled as having made a qualified disclaimer by the IRS.
Another option would be to request a private letter ruling
from the IRS.
Although it would be helpful to shipping companies for the IRS to issue a private letter ruling
determining whether or not a shipping company's activities are incidental to the international operation of ships, it is not certain that it will oblige such a request.
A Private Letter Ruling
issued in 2004, although it is not legal precedent binding on other tax-exempt organizations, confirms this position while adding insight from the IRS with regard to the rules applicable to unrelated business income subject to tax.
In practice, the need for this type of contract occurs when there are concerns about previous or future tax positions taken, or the IRS either will not issue a private letter ruling
or there is insufficient time to obtain one.
And the Internal Revenue Service has blessed their work with a Private Letter Ruling
* An Internal Revenue Service "private letter ruling
" allowed the application of U.S.
This can normally be done by requesting a private letter ruling
from the national office of the IRS.