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Private letter rulings (PLRs), in the United States, are written decisions by the Internal Revenue Service (IRS) in response to taxpayer requests for guidance.〔A description of procedures and current guidance is found at the IRS web page (How would I obtain a private letter ruling? ).〕 A letter ruling, or private letter ruling, is "a written statement issued to a taxpayer by an Associate Chief Counsel Office of the Office of Chief Counsel or by the Tax Exempt and Government Entities Division that interprets and applies the tax laws to a specific set of facts."〔Mitchell Rogovin & Donald L. Korb, "The Four R’s Revisited: Regulations, Rulings, Reliance, and Retroactivity in the 21st Century: A View From Within", 46 Duquesne Law Review 323, 342 (2008).〕 A private letter ruling binds only the IRS and the requesting taxpayer. Thus, a private ruling may not be cited or relied upon as precedent by other taxpayers. The IRS does have the option of redacting the personal content of a private ruling and issuing it as a revenue ruling, which becomes binding on all taxpayers and the IRS. (PLRs from 1997, forward, are available ) to the public through the IRS Electronic reading room. (see ). ==Similarity to Technical Advice Memorandum== A technical advice memorandum (TAM) is similar to a private letter ruling, but is typically (obtained ) during the course of an IRS examination. A TAM is generally issued by an IRS Associate Chief Counsel Office to an IRS Division Commissioner, or to an IRS Appeals Area Director. A TAM is issued after a request for assistance arising during "any proceeding" before the IRS.〔Mitchell Rogovin & Donald L. Korb, "The Four R’s Revisited: Regulations, Rulings, Reliance, and Retroactivity in the 21st Century: A View From Within", 46 Duquesne Law Review 323, 354 (2008).〕 The request for advice must concern the interpretation and application of the internal revenue laws, tax treaties, regulations, revenue rulings, or other precedents to a specific set of facts to determine the correct tax treatment for an item in a year under audit or on appeal. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Private letter ruling」の詳細全文を読む スポンサード リンク
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