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Private Letter Ruling A PLR may not be relied on as precedent by other taxpayers or IRS personnel. PLRs are generally made public after all information has been removed that could identify the taxpayer to whom it was issued.
First, it often takes the IRS a long time sometimes nine months or longer to issue a ruling. By that time, it may be too late for the PLR to provide any meaningful relief. Second, PLRs are expensive. As of July 1, 2022, the filing fee for requesting a PLR increased from $10,000 to $12,500.
Where fast-track handling is available, the IRS will endeavor to issue a private letter ruling in a compressed time frame, generally about 12 weeks. Outside of the fast-track process, the IRS generally aims to respond to ruling requests within 180 days of receipt, though more complex issues can take more time.
The Internal Revenue Bulletin is the authoritative instrument of the Commissioner for the announcement of official rulings, decisions, opinions, and procedures, and for the publication of Treasury decisions, Executive orders, tax conventions, legislation, court decisions, and other items pertaining to internal revenue
Rev. Proc. 2023-1 retains 2022 user fees (typically, $38,000 for private letter ruling requests; reduced fees of $3,000 and $8,500 for certain small organizations).
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Fees incurred by the taxpayer can range from $150 for simple requests to $50,000 for pre-filing agreements. For a specific transaction, a ruling can cost as much as $30,000, in addition to the professional fees that a taxpayer may incur.
Revenue rulings are published in the Internal Revenue Bulletin Cumulative Internal Revenue Bulletin.
Internal Revenue Service Agency overviewAnnual budget$14.3 billion (2022)Agency executiveDaniel Werfel, CommissionerParent agencyDepartment of the TreasuryWebsitewww.irs.gov6 more rows

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