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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CCA 200203053: Mirror sale-leasebacks lacked economic substance
A corporate group used paired domestic and foreign equipment sale-leasebacks, followed by a purported like-kind exchange, to generate rental deductions and foreign rental income sheltered by…
PLR 200203052: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203051: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203050: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203049: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203048: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203047: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203046: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203045: Funding family trust caused no gift or estate inclusion
A couple's joint living trust required a division into marital and family trusts after the first spouse died, but the estate tax return claimed a marital deduction for the entire trust residue. A…
PLR 200203044: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203043: Partnership contribution qualified for 1997 transition rule
Trusts agreed to contribute jointly held assets to a partnership, but court proceedings delayed the contribution until after June 8, 1997. A 1997 law extended from five to seven years the period in…
PLR 200203042: Conservation easement exchanged for ranch land
A ranch co-owner proposed to exchange a perpetual conservation easement over the existing ranch for an ownership interest in another ranch that would also carry a conservation easement. The IRS…
PLR 200203041: Late S election treated as timely from first tax year
A company intended to be taxed as an S corporation from its incorporation but did not file Form 2553 on time. It did timely file an S corporation income tax return for its first tax year. The IRS…
PLR 200203040: Revised nuclear decommissioning fund payment schedule approved
An electric utility with an ownership interest in a nuclear plant asked the IRS to revise the annual ruling amounts for its decommissioning fund. The IRS found that the proposed schedule used the…
PLR 200203039: Revised nuclear decommissioning fund payment schedule approved
An electric utility with an ownership interest in a nuclear plant asked the IRS to revise the annual ruling amounts for its decommissioning fund. The IRS found that the proposed schedule used one…
PLR 200203038: Revised nuclear decommissioning fund payment schedule approved
An electric utility with an ownership interest in a nuclear plant asked the IRS to revise the annual ruling amounts for its decommissioning fund. The IRS found that the proposed schedule used the…
PLR 200203037: Extension for disregarded entity classification election
A domestic corporation formed a domestic eligible entity and intended to elect for it to be disregarded as separate from its owner for federal tax purposes. The entity did not file Form 8832 on…
PLR 200203036: Extension for disregarded entity classification election
A domestic corporation formed a domestic eligible entity and intended to elect for it to be disregarded as separate from its owner for federal tax purposes. The entity had elected corporate…
PLR 200203035: Extension for disregarded entity classification election
A domestic corporation formed a domestic eligible entity and intended to elect for it to be disregarded as separate from its owner for federal tax purposes. The entity had elected corporate…
PLR 200203034: Proposed unitrust failed charitable remainder trust test
An S corporation proposed to contribute appreciated securities to a charitable remainder unitrust that would pay the corporation for 19 years and then its sole shareholder and the shareholder's…
PLR 200203033: Conservation easement exchanged for ranch land
Several ranch co-owners proposed to exchange a perpetual conservation easement over the existing ranch for an ownership interest in another ranch that would also carry a conservation easement. The…
PLR 200203032: Synthetic coal fuel facility qualified for section 29 rulings
A partnership purchased a facility that made solid synthetic fuel from coal and requested rulings about the section 29 production credit. Based on represented process details and testing, the IRS…
PLR 200203031: Extension to elect alternate estate valuation
An estate timely filed its federal estate tax return after obtaining an extension, but its personal representative did not clearly elect to value the estate six months after death under section…
PLR 200203030: Court-approved trust split preserved GST exemption
A trust that became irrevocable before September 25, 1985, had not received later additions and was exempt from generation-skipping transfer (GST) tax. Its trustees and beneficiaries disputed how…
PLR 200203029: Three-way trust division preserved GST exemption
A trust for a decedent's child had been irrevocable by September 25, 1985, with no later additions, making it exempt from generation-skipping transfer (GST) tax under the transition rule. Its…
CCA 200203028: Railroad retirement coverage had ended
The Railroad Retirement Board told the IRS that coverage of a redacted business under the Railroad Retirement Act had terminated effective February 23, 1998. After reviewing the Board's opinion and…
PLR 200203027: Condominium association received late election relief
A condominium management association had not filed income tax returns for several years because its officers did not know the filing requirements. It asked for more time to elect the tax treatment…
PLR 200203026: Related-person test for interest held through loan trust
A U.S. company planned to transfer consumer loans to a domestic trust, then sell trust certificates to a related controlled foreign corporation (CFC). It asked whether interest distributed on the…
CCA 200203025: Business ceased to be a railroad retirement tax employer
The Railroad Retirement Board advised the IRS that a redacted business ceased to be an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act effective April 20, 2001.…
CCA 200203024: Business became a railroad retirement tax employer
The Railroad Retirement Board advised the IRS that a redacted business became an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act effective April 2, 2001. Chief…
CCA 200203023: Business ceased to be a railroad retirement tax employer
The Railroad Retirement Board advised the IRS that a redacted business ceased to be an employer under the Railroad Retirement Act and Railroad Unemployment Insurance Act effective August 31, 1998.…
PLR 200203022: Late S election treated as timely from first tax year
A company intended to be taxed as an S corporation from its incorporation but did not file Form 2553 on time. The IRS found reasonable cause for the missed election deadline and ruled under section…
CCA 200203021: Former shareholder's creditor rights after redemption
A corporation redeemed most of its sole shareholder's stock with a secured installment note, while the shareholder sold the rest to his son and two employees. Chief Counsel analyzed whether the…
CCA 200203020: Executive pay deductions required factual apportionment
A U.S. manufacturer used a foreign sales corporation and calculated its combined taxable income under section 925. It apportioned some executives' compensation deductions between domestic and…
PLR 200203019: Aircraft cost transfers within one owner avoided air tax
A limited partnership owned three single-member limited liability companies, one of which held an aircraft used to transport employees of the others. The partnership and the other companies would…
CCA 200203018: Employer-signed section 83(b) elections met signature rule
An employer granted restricted property to employees and filed section 83(b) elections for them using powers of attorney the employees had signed. Several IRS service centers returned some forms,…
PLR 200203017: Managed property rents were not passive S corporation income
A real estate company with accumulated earnings and profits expected to elect S corporation status and asked whether rent from its retail, warehouse, and self-storage properties counted as passive…
CCA 200203016: Reinsurance refunds accrued when losses became clear
A medical malpractice insurer paid reinsurance premiums under a contract with a notional experience account that could refund amounts depending on claims losses. The insurer reduced premiums earned…
PLR 200203015: Foreign share exchange received section 367 exception
U.S. shareholders planned to exchange stock of a domestic target for shares of a foreign acquiring corporation in a larger cross-border transaction. Section 367(a)(1) generally makes such outbound…
TAM 200203014: Low-income housing credit advice applied retroactively
A partnership that owned a low-income housing project asked the IRS to apply an earlier technical advice memorandum only prospectively. The earlier advice had excluded or limited several project…
TAM 200203013: Housing credit relief denied for costs, fee issue suspended
A low-income housing partnership asked the IRS to apply earlier technical advice about its project's eligible credit basis only prospectively. The earlier advice addressed land preparation costs,…
TAM 200203012: Low-income housing credit advice applied retroactively
A partnership that owned a low-income housing project asked the IRS to apply an earlier technical advice memorandum only prospectively. The earlier advice had limited land preparation costs and…
TAM 200203011: Low-income housing credit advice applied retroactively
A partnership that owned a low-income housing project asked the IRS to apply an earlier technical advice memorandum only prospectively. The earlier advice had excluded or limited land preparation…
PLR 200203010: Insurance settlement fully taxable with business deductions
A sole proprietor was sued after someone was injured during a business workshop, then recovered a settlement from an insurer that had withdrawn her defense. The settlement paid portions directly to…
CCA 200203009: Depreciation treatment of hotel and casino property
Chief Counsel advised on depreciation classifications for a hotel and casino complex. An asset used for both hotel and casino operations belongs in the class for its primary use, rather than having…
PLR 200203008: Revised nuclear decommissioning fund schedule approved
A utility requested a revised schedule of ruling amounts for contributions to a qualified nuclear decommissioning fund. The taxpayer represented that it owned an interest in a nuclear plant, filed a…
CCA 200203007: Bankruptcy and the agent for a consolidated group
Chief Counsel analyzed a consolidated corporate group whose members held partnership interests, underwent downstream mergers, and later entered bankruptcy. It advised that a bankrupt member's…
PLR 200203006: Estate reports interest and dividends when received
An estate sought the proper year to report interest and dividends on a deceased person's United States accounts and stock. Its foreign administrator could not directly collect the assets, and a…
CCA 200203005: Disabled insurance agent did not qualify as a statutory employee
Chief Counsel advised an IRS unit to revoke its earlier determination that a disabled life insurance agent was a statutory employee for 1998. The firm kept the agent's contract in force mainly so he…
CCA 200203004: Airline cannot deduct estimated voucher flight costs early
An accrual method airline issued travel vouchers after unsatisfactory customer experiences and sought to deduct estimated costs of future flights when it issued the vouchers. Chief Counsel advised…
CCA 200203003: Review frivolous employment tax filings case by case
Chief Counsel advised how to handle employment tax filings that incorrectly claimed an exemption under section 861. A Form 941 with Form 941c attached could still be a valid return if it contained…
CCA 200203002: Processing letter did not start refund suit deadline
A taxpayer filed amended income tax returns seeking a refund based on a net operating loss carryback. The IRS sent a letter saying it could not process a claim because a Tax Court decision had been…
TAM 200203001: Equipment in an active leasing business is depreciable
A heavy equipment dealer both sold equipment and leased it to customers, often leasing the same item several times before its eventual sale. The IRS concluded that equipment committed to the…
CCA 200202072: A section 911 election may continue into later years
An IRS unit asked whether a taxpayer's earlier Form 2555 election to exclude foreign earned income remained effective for a later year, even though the later return and Form 2555 were late. Chief…
CCA 200202071: Signature requirements for filing extension forms
Chief Counsel answered which extension of time to file forms required a signature under the rules then in effect. It advised that Forms 4868 and 8736 did not require signatures for IRS approval,…
IRS bulletin 200202070: Collection, bankruptcy, and summonses advice
This IRS Chief Counsel bulletin combines case summaries with previously released advice on tax collection and bankruptcy. One advice piece says annual installment agreement statements need not be…
CCA 200202069: EITC disallowance requires deficiency procedures
Chief Counsel advised IRS staff on procedures for reducing or disallowing the earned income tax credit (EITC). Because the EITC counts as a negative amount of tax in the deficiency calculation, the…
CCA 200202068: Offhighway truck exception requires two tests
Chief Counsel addressed whether modified dump trucks could avoid the section 4051 retail excise tax as offhighway vehicles. It advised that a vehicle must be specially designed mainly to carry a…
PLR 200202067: Extension granted for section 338 elections
A consolidated group intended to make section 338(g) elections after its member bought stock of foreign corporations, but valid elections were not filed by the deadline. The IRS found that the…
PLR 200202066: Extension granted for joint section 338(h)(10) election
A consolidated group and the shareholders of an S corporation intended to make a joint section 338(h)(10) election after a stock purchase, but a valid election was not filed on time. The IRS found…
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.