Revenue Rulings

Revenue Rulings

Overview

A revenue ruling is an official interpretation by the IRS of the Internal Revenue Code, related statutes, tax treaties and regulations. It is the conclusion of the IRS on how the law is applied to a specific set of facts. Revenue rulings are published in the Internal Revenue Bulletin for the information of and guidance to taxpayers, IRS personnel and tax professionals. For example, a revenue ruling may hold that taxpayers can deduct certain automobile expenses.

“Revenue Rulings, which address issues of substantive tax law, arise from various sources, including rulings to taxpayers, technical advice to district offices, studies undertaken by the IRS, court decisions, suggestions from practitioner groups, and so on. A revenue ruling is the Commissioner’s ‘official interpretation of the interpretation of the law’ and generally is binding on revenue agents and other IRS officials. Courts typically give revenue rulings far less weight than regulations, regarding them simply as the Commissioner’s view of the law. The IRS states that taxpayers generally may rely on published revenue rulings in determining the tax treatment of their own transaction that arise out of similar facts and circumstances.” Graetz, Federal Income Taxation: Principles and Policies, p. 73 (2nd ed. 1988) (Foundation Press).

The IRS began issuing numbered revenue rulings in 1953. They adopted the current numbering system in 1954.

Access Revenue Rulings in the Encyclopedia

The American Tax Encyclopedia has the goal of providing direct access to all available revenue rulings. At the present time, however, only revenue rulings since mid-2003, along with selected older revenue rulings, have been put onto the site. New rulings are added periodically, not necessarily concurrent with actual release. Please see the references below for alternate sources.

1950s 1954 1955 1956 1957 1958 1959
1960s 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969
1970s 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979
1980s 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989
1990s 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999
2000s 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
2010s 2010 2011 2012 2013 2014 2015 2016

Locating Revenue Rulings with Vendors

Revenue Rulings are available in:

  • Westlaw: Westlaw (formerly FTX-RR Database. Westlaw platform contains Revenue Rulings released by the IRS and selected for publication in the IRB from 1954 to the present.
  • Lexis: Lexis (formerly FEDTAX;CB Database) The Lexis platform contains Revenue Rulings released by the IRS and selected for publication in the IRB since January 1, 1981.
  • Print and Online Sources:

    • CCH’s Standard Federal Tax Reporter contains annotations to Revenue Rulings in its compilation volumes following each IRC section. CCH’s online product, CCH Tax Research NetWork, contains the text of Revenue Rulings in the Federal Tab in the “Rulings & Other Docs.” section under Primary Sources.
    • RIA’s United States Tax Reporter contains annotations to Revenue Rulings in its compilation volumes following each IRC section. RIA’s online product, RIA Checkpoint, contains the text of Revenue Rulings which can be accessed via the “Rulings/IRB” section on the left side of the screen under Find By Citation or by searching in the “IRS Rulings and Releases” database under the Primary Source Materials heading.
    • Print Sources: Internal Revenue Bulletin, Cumulative Bulletin.

    Other Sources for Revenue Rulings

    Citing Revenue Rulings

    Citing Revenue Rulings in the Bluebook

    See Bluebook Rule 14.5.2(a) and cite to the Cumulative Bulletin or the Internal Revenue Bulletin, in that order of preference.

    Example: Rev. Rul. 83-137, 1993-3-2 C.B. 41.


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