Federal Tax Law Research: Locating and Citing Private Letter Rulings

Locating and Citing Private Letter Rulings

Locating Private Letter Rulings

Private Letter Rulings are published in:

Westlaw: FTX-WD and FTX-PLR These databases contain Private Letter Rulings from 1954 to the present.
Lexis: FEDTAX;PLR This database contains Private Letter Rulings from 1954 to the present.

IRS Website: http://www.irs.gov/foia/lists/0,,id=97705,00.html This website, within the IRS's Electronic Reading Room, contains the text of some Private Letter Rulings from 1997 to the present.

Print and Online Sources:

CCH's Standard Federal Tax Reporter contains annotations to Private Letter Rulings in its compilation volumes following each IRC section. CCH's online product, CCH Tax Research NetWork, contains the text of Private Letter Rulings in the Federal Tab in the "Rulings & Other Docs." section under Primary Sources.
RIA's United States Tax Reporter contains annotations to Private Letter Rulings in its compilation volumes following each IRC section. RIA's online product, RIA Checkpoint, contains the text of Private Letter Rulings which can be accessed via the "Rulings/IRB" section on the left side of the screen under Find By Citation or by searching in the "IRS Rulings and Releases" database under the Primary Source Materials heading.

Print Sources:

IRS Letter Rulings Reporter KF 6289 .A353
CCH's IRS Positions Reporter KF 6300 .A833

Citing Private Letter Rulings

See Bluebook Rule 14.5.2(b).

Example:

Priv. Ltr. Rul. 86-1-012 (Sept. 30, 1985)