ruling

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Related to Private Rulings: Private Letter Rulings

ruling

[′rül·iŋ]
(mathematics)
One of the positions of the straight line that generates a ruled surface.
References in periodicals archive ?
Subsequent private rulings, including the recently issued private letter rulings, have been consistent with Rev.
According to these data, the average yearly number of private ruling requests for that period was 1,652 (excluding technical requests for a change in the accounting method or a change in the accounting period, which are processed as rulings but are not published).
While these rulings may signal a more reasonable approach by the IRS, advisors must still deal with IRA providers and custodians who may be unwilling to make beneficiary distributions in reliance on the nuances of private rulings, which technically are not reliable as precedent.
Many revenue rulings, technical advice memorandums, private rulings, and court cases have addressed these issues in substantial detail.
The preamble to the Proposed Regulations provides that the rules were issued in response to the increased number of private ruling requests involving application of section 7704(d)(1)(E), as opposed to a change in policy or other concerns regarding these entities.
36) Shortly before the enactment of section 6110, however, two courts had already held private rulings to be open to public inspection, pursuant to the FOIA.
Lastly, numerous private rulings regarding corporate and shareholder eligibility will be discussed.
Cohen said limitations placed on the areas for which the IRS will issue private rulings, including consolidated returns and corporation reorganization under Internal Revenue Code section 355, have freed up resources that can be concentrated on issuing regulations and rulings for areas that have no clear guidance.
Part of that bitterness no doubt stemmed from the rule that Department attorneys were not permitted to cite any of these private rulings because of the express statutory prohibition against using them as precedent.
As a result, practitioners have had to rely on a relatively limited (and occasionally conflicting) number of published and private rulings in this area.
There is a natural sensitivity to situations involving a controlling shareholder, and the IRS would not issue private rulings in that case.

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