Private letter ruling

Private letter rulings (PLRs), in the United States, are written decisions by the Internal Revenue Service (IRS) in response to taxpayer requests for guidance.^[1] 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. The IRS does have the option of redacting the text of a private ruling and issuing it as a revenue ruling, which becomes binding on all taxpayers and the IRS. Some private letter rulings are ultimately published as a public Revenue ruling and become binding on the IRS for all taxpayers. PLRs are available to the public through the IRS Electronic reading room. (see 26 U.S.C. § 6110).