Question

Subject: Business Tax Sally Andrews calls you on the phone. She says that she has found...

Subject: Business Tax

Sally Andrews calls you on the phone. She says that she has found a 2007 letter ruling that agrees with a position she wants to take on her tax return. She asks you about the precedential value of a letter ruling. Draft a memo for the tax files, outlining what you told Sally.

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Answer #1

Answer:

What is Private Letter Ruling:

Sometimes Taxpayer may need some clarification regarding interpretation of tax law or they may be disagree with interpretation of law. Then they may ask Internal Revenue Service (IRS) office to issue a ruling on specified point. It is regarded as "Private letter ruling".

Legal Value of letter ruling:

Legal value of Private letter ruling is very restricted i.e. it applies only to those taxpayer who request for it and only for a transaction for which it was sought.

Hence, Sally Andrews cannot take a benefit of 2007 letter ruling. She has to take new letter ruling for her transaction.

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