IRS Definition of Revenue Rulings

8.6.3.1  (10-26-2007)
Definition of Revenue Rulings

  1. A revenue ruling is an official interpretation by the IRS of the tax laws, related statutes, treaties, and regulations published in the Internal Revenue Bulletin. The following is a list of offices that issue revenue rulings based upon their specialized subject matters:

    • Office of Associate Chief Counsel (Corporate)

    • Office of Associate Chief Counsel (Financial Institutions & Products)

    • Office of Associate Chief Counsel (Income Tax & Accounting)

    • Office of Associate Chief Counsel (International)

    • Office of Associate Chief Counsel (Passthroughs & Special Industries)

    • Associate Chief Counsel (Procedure and Administration)

    • Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities).

  2. Revenue rulings do not have the force and effect of Treasury Regulations (including Treasury decisions), but are published to provide precedents to use in the disposition of other cases, and may be cited and relied upon for that purpose.

  3. However, when applying revenue rulings, consider the effect of subsequent legislation, regulations, court decisions, revenue rulings, and revenue procedures. Appeals personnel are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.

  4. Secure information on the status of certain issues, which may be under active consideration in Chief Counsel's Office for publication as a revenue ruling, from the Appeals Director, Technical Services.


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