Private Letter Ruling

A taxpayer may, for a fee, seek advice from the IRS as to the proper tax treatment of a transaction. A private letter ruling binds only the IRS and the requesting taxpayer. Thus, a private ruling may not be cited or relied upon for precedent. The IRS does have the option of redacting the text of a private ruling and issuing it as a revenue ruling, which become binding on all taxpayers and the IRS.