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Private Letter Ruling 09-007

Private Letter Ruling 09-007 2025

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The document is a Private Letter Ruling request submitted to the Utah State Tax Commission regarding whether Company A (Dealer) should collect sales tax from Company B (Manager) for refurbishment services provided to trailers owned by Company C (Owner). The ruling concludes that Dealer is not required to collect sales tax from Manager, as the refurbishment services are performed outside of Utah, and thus do not meet the substantial nexus requirement for taxation under Utah law.

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How does a private letter ruling work?

A private letter ruling, or PLR, is a written statement issued to a taxpayer that interprets and applies tax laws to the taxpayers represented set of facts. A PLR is issued in response to a written request submitted by a taxpayer.

Do private letter rulings deal with completed transactions?

Private letter rulings explain the Departments application of tax statutes, tax rules, and general tax principles to a taxpayers specific proposed or completed transaction. Private letter rulings are generally binding upon the Department, but may only be relied upon by the taxpayer to whom they are issued.

Is a private letter ruling the same as a determination letter?

Common abbreviations the you may encounter for private letter rulings are PLR and LTR, both indicate the same item. A determination letter is similar in purpose and nature to a private letter ruling, except that it is issued by the office of the local IRS district director not the national office of the IRS.

Can a private letter ruling be used as precedent?

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.

Can you rely on a private letter ruling?

The general rule concerning the issue presented is that a private letter ruling may be relied upon only by the taxpayer to whom it was issued.

Where may private letter rulings be found?

Where may private letter rulings be found? Letter rulings may be found in: Private Letter Rulings (RIA). BNA Daily Tax Reports.

Private Letter Ruling 09-007 2025

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How does a private letter ruling work?

Do private letter rulings deal with completed transactions?

Is a private letter ruling the same as a determination letter?

Can a private letter ruling be used as precedent?

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Private Letter Ruling 09-007 2025

Here's how it works

How to rapidly redact Private Letter Ruling 09-007 online

Complete this form in 5 minutes or less

Got questions?

How does a private letter ruling work?

Do private letter rulings deal with completed transactions?

Is a private letter ruling the same as a determination letter?

Can a private letter ruling be used as precedent?

Can you rely on a private letter ruling?

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Where may private letter rulings be found?

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