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 200707157: Spousal IRA rollover waiver denied after funds enter checking account
A surviving spouse requested relief after her husband's IRA was distributed into a checking account instead of being transferred to an IRA in her name. She said bank staff had told her the transfer…
PLR 200707156: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707155: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707154: Four government wind projects denied clean-energy bond allocations
An applicant sought authority to issue Clean Renewable Energy Bonds for four wind facilities owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, including no…
PLR 200707153: Ten solar projects receive clean renewable energy bond allocations
An issuer applied for authority to finance ten solar energy facilities with Clean Renewable Energy Bonds. The IRS determined that the listed projects qualified under IRC § 54, would have qualified…
PLR 200707152: Six solar projects receive bond allocations while three are denied
An issuer sought Clean Renewable Energy Bond authority for solar energy projects. The IRS approved allocations for the six qualified projects in Appendix A, with redacted amounts for each. Bonds…
PLR 200707151: Landfill gas project receives clean renewable energy bond allocation
An issuer applied for authority to finance a landfill gas facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified…
PLR 200707150: Government biomass project denied bond allocation at funding cap
An applicant sought authority to issue Clean Renewable Energy Bonds for an open-loop biomass facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million,…
PLR 200707149: Six government wind projects denied clean-energy bond allocations
An applicant sought authority to issue Clean Renewable Energy Bonds for six wind facilities owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, including no…
PLR 200707148: Biomass project receives clean renewable energy bond allocation
An issuer applied for authority to finance a open-loop biomass facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have…
PLR 200707147: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707146: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707145: Government solar project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a solar energy facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no…
PLR 200707144: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707143: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707142: One wind project receives bond allocation and another is denied
An issuer applied for Clean Renewable Energy Bond authority for two wind projects. The IRS approved a redacted allocation for the project in Appendix A under IRC § 54. It denied the governmental…
PLR 200707141: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707140: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707139: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707138: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707137: Government landfill-gas project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a landfill-gas facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no…
PLR 200707136: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707135: Government trash-combustion project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a trash-combustion facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with…
PLR 200707134: Forty-seven solar projects receive bond allocations and two are denied
An issuer sought Clean Renewable Energy Bond authority for solar energy projects. The IRS approved allocations for the 47 projects in Appendix A under IRC § 54. It denied the two governmental…
PLR 200707133: Government trash-combustion project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a trash-combustion facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with…
PLR 200707132: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707131: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707130: Two solar projects receive clean renewable energy bond allocations
An issuer applied for authority to finance two solar energy facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified…
PLR 200707129: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707128: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707127: Solar project receives clean renewable energy bond allocation
An issuer applied for authority to finance a solar energy facility with Clean Renewable Energy Bonds. The IRS determined that the project qualified under IRC § 54, would have qualified ownership,…
PLR 200707126: Seven solar projects receive clean renewable energy bond allocations
An issuer applied for authority to finance seven solar energy facilities with Clean Renewable Energy Bonds. The IRS determined that the projects qualified under IRC § 54, would have qualified…
PLR 200707125: Landfill gas project receives clean renewable energy bond allocation
An issuer applied for authority to finance a landfill gas facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified…
PLR 200707124: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707123: Solar project receives clean renewable energy bond allocation
An issuer applied for authority to finance a solar energy facility with Clean Renewable Energy Bonds. The IRS determined that the project qualified under IRC § 54, would have qualified ownership,…
PLR 200707122: Ninety-three solar projects receive bond allocations and one is denied
An issuer sought Clean Renewable Energy Bond authority for solar energy projects. The IRS approved allocations for the 93 projects in Appendix A under IRC § 54. It denied the governmental project in…
PLR 200707121: Two landfill-gas projects receive bond allocations and six other projects are denied
An issuer sought Clean Renewable Energy Bond authority for landfill-gas and hydropower projects. The IRS approved allocations for the two landfill-gas projects in Appendix A under IRC § 54. It…
PLR 200707120: Government biomass project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for an open-loop biomass facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with…
PLR 200707119: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707118: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707117: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707116: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707115: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707114: Government biomass project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a biomass facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more…
PLR 200707113: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707112: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707111: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707110: Ten solar projects receive bond allocations and one is denied
An issuer sought Clean Renewable Energy Bond authority for solar energy projects. The IRS approved allocations for the ten projects in Appendix A under IRC § 54. It denied the governmental project…
PLR 200707109: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707108: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707107: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707106: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707105: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707104: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707103: Government wind project denied bond allocation after funding cap is reached
An applicant sought authority to issue Clean Renewable Energy Bonds for a wind facility owned by a governmental borrower. IRC § 54 limited the overall allocations to $800 million, with no more than…
PLR 200707102: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707101: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707100: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707099: Wind project receives clean renewable energy bond allocation
An issuer applied for authority to finance a wind facility with Clean Renewable Energy Bonds. The IRS determined that the described project qualified under IRC § 54, would have qualified ownership,…
PLR 200707098: Seven solar projects receive bond allocations and two are denied
An issuer sought Clean Renewable Energy Bond authority for solar energy projects. The IRS approved allocations for the seven projects in Appendix A under IRC § 54. It denied the two governmental…
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.