IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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Revised nuclear decommissioning fund schedule approved
A regulated public utility requested a revised schedule of deductible contributions to its nuclear decommissioning fund after shutting down a plant and beginning decommissioning. The proposed schedule…
Revised decommissioning schedule approved after rate reduction
A public utility requested a revised schedule of contributions to its nuclear decommissioning fund after its regulator reduced the decommissioning costs included in rates. The reduction meant that pri…
Nuclear fund schedule revised after regulated costs declined
A public utility requested a revised schedule of contributions to its nuclear decommissioning fund after its regulator reduced the decommissioning costs included in rates. The reduction meant that pri…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.