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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Three partnerships may make late section 754 elections
Three limited liability companies treated as partnerships failed to make section 754 elections for the year in which an owner died. A section 754 election allows partnership property basis adjustments…
Advance construction payments create partnership liabilities
A partnership entered long-term contracts to design and build industrial facilities and received certain payments before performing the related work or reporting the income. The partnership secured it…
Partner guarantee shifts basis and at-risk treatment
An LLC taxed as a partnership acquired, renovated, and held hotel properties, while a separate manager handled daily hotel operations. One member personally guaranteed partnership notes, and another m…
Partnership receives 120-day extension for section 754 election
An LLC taxed as a partnership intended to elect under section 754 to adjust the basis of partnership property but inadvertently failed to file a properly executed election with its return. The partner…
Partnership conversion continues without termination or recognition
A disregarded limited partnership owned an interest in another partnership. After a new investor exchanged its interest in the lower-tier partnership for an interest in the upper-tier entity, the lowe…
Partnership receives 120 days to make section 754 election
A partnership timely filed its return for a year in which ownership interests were transferred but did not make a section 754 election or reflect the related basis adjustments. The partnership represe…
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.