Ezel / IRS Rulings / 200302049

PLR 200302049: IRS revokes three prior private letter rulings

Number
200302049
Outcome
Revocation
Document type
Determination Letter
IRS subject
Termination of Private Foundation Status
Topics
Tax-exempt organizations
Code sections
§ 507
Ruling dated
October 16, 2002
Publicly released
January 10, 2003
Source
View Official PDF

Apply this to your situation

This page covers one taxpayer's determination, issued in 2003, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2003
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

The IRS revoked three private letter rulings issued to the same taxpayer in response to a 1997 ruling request. The IRS stated that the rulings contained inconsistent legal positions and that the taxpayer had accepted the revocation. The letter cites the procedure for revoking a ruling that is erroneous or no longer accords with the Service's current views.

Ruling snapshot

  • Question: Should the IRS revoke three prior private letter rulings because their legal positions were inconsistent?
  • Outcome: Revocation.
  • Key authorities: Rev. Proc. 2002-4, § 13.04, 2002-1 I.R.B. 127; IRC § 507.

Full text (IRS public release)

200302049

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224

TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION

OCT 16 2002

SIN: 507.00-00

T:EO:B3

Dear
:

The purpose of this letter is to revoke private letter rulings 199823057, 199913034 and 199952090 issued to you in response to a letter ruling request dated December 22, 1997.

A private letter ruling found to be in error or not in accord with the current views of the Service may be revoked. Section 13.04, Rev. Proc. 2002-4, 2002-1 I.R.B. 127. Because of inconsistencies in the legal position taken in these rulings, we hereby revoke them. You have previously accepted this action.

This ruling is directed only to the taxpayer that requested it. Section 6110(k) of the Code provides that it may not be used or cited as precedent.

A copy of this letter has been sent to your authorized representative in accordance with a power of attorney on file in this office.

Sincerely,

(signed) Robert C. Harper, Jr.

Robert C. Harper, Jr.
Manager, Exempt Organizations
Technical Group 3

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