A revenue ruling is an official IRS interpretation of the tax law as it applies to specific factual situations. Taxpayers are expected to rely on these rulings when deciding upon the most appropriate tax treatment of their own taxable transactions. A taxpayer who ignores an applicable revenue ruling when preparing a tax return can be subject to fines and penalties. If there is no revenue ruling that applies to the specific circumstances of a taxpayer, the taxpayer can apply to the IRS for advice, which results in a private letter ruling. The IRS requires that a fee be paid before it will issue a private letter ruling. The IRS may elect to convert a private letter ruling into a revenue ruling, thereby making it binding on all IRS employees and taxpayers.
Revenue rulings are intended to provide guidance to IRS employees in how they interpret the tax law when dealing with taxpayers.
Revenue rulings are published in the Internal Revenue Bulletin and the Federal Register.