Tax Complexity

A Private Letter Ruling is a letter the IRS issues to a particular taxpayer—corporate or business—to provide specific instructions/clearance to a specific taxpayer about that taxpayer’s particular circumstance.  PLRs set no precedent for any other taxpayer; even if that other has a substantially similar circumstance.  The price for such a Letter, charged by the IRS to the Letter’s recipient, ranges from $2,200 to $28,300.

The procedure for getting a PLR is set out in Internal Revenue Bulletin:  2016-1, which runs past 260 .pdf pages (the Table of Contents runs nearly 6 pages).  There’s a hint there.

Here’s another hint, from the opening paragraph of 2016-1‘s Section 1, which lays out the purpose of this procedure:

This revenue procedure explains how the Service provides advice to taxpayers on issues under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Associate Chief Counsel (Tax Exempt and Government Entities). It explains the forms of advice and the manner in which advice is requested by taxpayers and provided by the Service. A sample format for a letter ruling request is provided in Appendix B. See section 4 of this revenue procedure for information on certain issues outside the scope of this revenue procedure on which advice may be requested under a different revenue procedure.

Seven different tax specialist head lawyers are needed by the IRS to explain the IRS’ own tax rules to prospective tax advice seekers.


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