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in this video were going to look at requests for private letter rulings and determination letters before the irs so tax practitioners occasionally find it necessary to seek a letter ruling from the irs regarding the consequences of a clients anticipated business transactions or to settle a disagreement with the revenue agent during an examination without a favorable ruling the taxpayer may decide not to engage in the transaction now difference between letter ruling and determination letter the general procedures with respect to letter rulings which the private letter rulings are before the fact so anticipated transactions and determination letters after the fact where again you might be disagreeing uh with a revenue agent during an examination are outlined in the first revenue procedure issued each year the irs has announced that a careful adherence to these procedures will minimize delays in processing requests for letter rulings and determination letters so the idea here if you hav