See rev proc 5 1 irb 233 Form 2021-2024

See rev proc 2024 5 2024 1 irb 233 Form: What You Should Know

Taxpayers requesting the issuance of letter rulings should be mindful of the following three principles: the taxpayer should seek and have received a determination letter of the correct tax due. The Associate will not provide a letter ruling unless the Taxpayer requests the issuance of the letter ruling and demonstrates to the Associate that a letter ruling is necessary to determine a Taxpayer's account tax liability. The Associate will not accept the proof of tax liability required by the Taxpayer, unless the Commissioner approves the proof. If the Associate does not receive a request for a letter ruling, he/she must inform the Taxpayer that the Taxpayer will not have the correct tax due on their account, and that the Taxpayer should contact a State revenue officer (i.e., their state tax agency) to pursue the case. This procedure also provides guidance to individuals who provide information to the IRS regarding the proper assessment of tax liabilities. If the Taxpayer requests a letter ruling from the IRS and the Associate does not grant the request, the IRS cannot accept a copy of the letter ruling that would include an explanation that the Taxpayer is not entitled to a letter ruling because the IRS is not a federal agency; the letter ruling was issued by an 'Internal Revenue Agent' (see Rev. Pro. 2021-3, 2011-18 Run. 1, para. 16) (this applies to state tax agents who have the authority to issue 'tax rulings'). Accordingly, any requests for information or letter rulings from the IRS would generally be denied, if the IRS ever receives a request for letter rulings. However, if you have a claim in your Form 1040 or 1040A that shows the right tax period was determined incorrectly, you should seek to have that assessment corrected. Once the Associate determines the correct tax period is being assessed, a letter ruling may be issued by the IRS within 10 days if the Associate does not have all the required information to complete the letter ruling.

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