IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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PLR 1050042: Five-year pension amortization extension approved
The IRS approved a five-year automatic extension for a pension plan to amortize specified unfunded liabilities. The plan qualified because, without the extension, it would have an accumulated…
PLR 1049042: IRS waived the 60-day IRA rollover deadline after bank error
The IRS waived the 60-day deadline for an individual to roll an IRA distribution into another IRA. The taxpayer had instructed a bank to deposit the distribution into an IRA rollover account, but…
PLR 1048046: IRS waives the 60-day IRA rollover deadline
An individual received a distribution from an IRA and instructed a financial institution to place the money into an IRA, but the institution opened a non-IRA account instead. The institution later…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.