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 1049009: Nuclear decommissioning fund schedules are approved
This ruling addresses a utility's requests for a schedule of deduction amounts and a revised schedule of ruling amounts for contributions to a nuclear decommissioning fund. The IRS concluded that…
PLR 1049008: Trust modifications will preserve a zero GST inclusion ratio
This ruling addresses a court-approved modification of an irrevocable trust with a zero generation-skipping transfer tax inclusion ratio. The modification would split the trust into three family…
PLR 1049007: Cooperative grower payments qualify as per-unit retain allocations
This ruling addresses a farmers' cooperative that processes and markets members' and nonmembers' crops. The IRS concluded that the cooperative's cash grower payments, including initial, interim,…
PLR 1049006: Upstream merger will not trigger gain on installment note
This ruling addresses a proposed upstream merger in which a subsidiary would transfer an installment note to its parent. The IRS concluded that the transfer would not be a taxable disposition of the…
PLR 1049005: Nuclear decommissioning fund schedules are approved after an ownership transfer
This ruling addresses a taxpayer that acquired an ownership interest in a nuclear power plant and the related qualified decommissioning funds. The IRS approved a schedule of deduction amounts for a…
PLR 1049004: Taxpayers receive more time to make consent dividend elections
A corporate group asked for more time to make consent dividend elections after discovering that a subsidiary had been a personal holding company for several years. The IRS concluded that the…
PLR 1049003: University venue agreement does not trigger the private business use test
A university and a public authority asked whether a media company's rights under an agreement would create private business use of improvements financed with tax-exempt bonds. The agreement covered…
PLR 1049002: Late S corporation election is accepted for reasonable cause
A corporation intended to elect S corporation status from its incorporation date but did not timely file Form 2553. The IRS concluded that the corporation established reasonable cause for the late…
PLR 1049001: IRS denies § 9100 relief for late DISC election
A domestic corporation asked for more time to file Form 4876-A to elect interest charge DISC status for an earlier tax year. The IRS determined that the applicable election deadline came from the…
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…
CCA 1048043: AAR issues are handled in the FPAA after an NBAP is issued
Chief Counsel Advice addresses a TEFRA partnership-proceeding question involving an administrative adjustment request. The memorandum states that once a notice of beginning of administrative…
CCA 1048042: Inconsistent partner reporting can support assessment without an FPAA
Chief Counsel Advice considers partners who reported liabilities inconsistently with the partnership return without filing Form 8082, Notice of Inconsistent Treatment. The memorandum states that the…
CCA 1048041: Determination-letter revocation would apply prospectively after notice
Chief Counsel Advice discusses how a determination letter could be revoked prospectively. The memorandum states that the revocation would be effective only after the taxpayer was notified of the…
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.