Question: Sometimes a private letter ruling is generalized and included in
Sometimes a private letter ruling is generalized and included in an official IRS publication. What form does this recast private ruling take?
Answer to relevant QuestionsWhat is a determination letter? Which office of the IRS issues determination letters? What kinds of issues are addressed therein? Explain each of the elements of this citation: Ltr. Rul. 9615032. In what publication(s) would a tax researcher find the official listing of the IRS acquiescences and nonacquiescences to a Tax Court decision? What is an IRS notice? When is it used? In your opinion, could a tax practitioner rely on an IRS notice as authority for a tax return position? Ned Naive operated several franchised stores, and at the home office’s suggestion he consolidated the stores’ payroll and accounting functions with Andy the Accountant. Andy is not a CPA. Last year, Andy began embezzling ...
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