A Private Letter Ruling (PLR) is a written response by the
Internal Revenue Service (IRS) to a taxpayer's request for information. A PLR can be used by a taxpayer for guidance on whether to take particular actions. The IRS regularly release PLRs. However, PLRs may not be cited to the courts and the IRS has the option to redact the rulings.
PLRs may be published by the IRS. If so, a PLR becomes a Revenue Ruling. Revenue Rulings are binding on the IRS and taxpayers. Revenue Rulings may be used as precedent in court. Revenue Rulings are conclusions by the IRS on how federal law applies to particular fact patterns.
Private Letter Rulings and Revenue Rulings can provide excellent guidance in assisting an estate litigation attorney. PLRs can help the attorney understand the view of the IRS and assist the attorney in guiding their clients through areas of law on fact patterns that may not have been addressed by the courts.