IRS National Office Procedures — Rulings, Closing Agreements (Portfolio 621)

Description

Tax Management Portfolio, IRS National Office Procedures — Rulings, Closing Agreements, No. 621, discusses the procedures for requesting rulings, determination letters, technical advice, closing agreements, and other types of guidance, from the Internal Revenue Service. The Portfolio also discusses the circumstances in which guidance is available and the effect of that guidance once it is issued. The retroactive effect of a revocation or modification of an IRS pronouncement is discussed in detail.

The procedures for obtaining IRS guidance are intended to minimize controversies, enhance tax planning, and improve relations between the IRS and taxpayers. However, these procedures are normally helpful to a taxpayer only if the taxpayer knows how to use them and is fully aware of their legal and practical effects.

Table of Contents

I. Introduction
II. Letter Rulings
III. Determination Letters
IV. Technical Advice
V. Revenue Rulings and Revenue Procedures
VI. Other IRS Pronouncements
VII. Closing Agreements