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Ezel / IRS Rulings / 201550039
Chief Counsel Advice 201550039 Released December 11, 2015 Advice

IRS office may use an unredacted private letter ruling

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This page covers one taxpayer's ruling from 2015, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2015
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advised that the relevant IRS office should have an unredacted copy of a private letter ruling available for use in addressing a question about self-created goodwill. If that office had destroyed its copy under its records-retention schedule, the employee asking the question could provide another copy.

Ruling snapshot

  • Question: How could an IRS employee provide the relevant office with an unredacted private letter ruling?
  • Outcome: Advice given
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2015110615112647
UILC: 6103.08-00

Number: 201550039
Release Date: 12/11/2015
From:
Sent: Friday, November 06, 2015 3:11:26 PM
To:
Cc:
Bcc:
Subject: RE: Question regarding use of plr for self-created goodwill?

I am in ------(Branch 7) and not in the ----------------------, and ------------ branch (------), but
it is my understanding that ------ should have an un-redacted version available. If for
some reason ------ has destroyed the PLR due to their retention schedule, you can
provide ------ your copy.

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