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The Department of the Treasury’s statement of procedural
rules, contained in the regulations, provides in relevant part:
(2) Objectives and standards for publication of
Revenue Rulings and Revenue Procedures in the Internal
Revenue Bulletin.--(i)(a) A “Revenue Ruling” is an
official interpretation by the Service that has been
published in the Internal Revenue Bulletin. Revenue
Rulings are issued only by the National Office and are
published for the information and guidance of
taxpayers, Internal Revenue Service officials, and
others concerned.
* * * * * * *
(iii) The purpose of publishing revenue rulings
and revenue procedures in the Internal Revenue Bulletin
is to promote correct and uniform application of the
tax laws by Internal Revenue Service employees and to
assist taxpayers in attaining maximum voluntary
compliance by informing Service personnel and the
public of National Office interpretations of the
internal revenue laws, related statutes, treaties,
regulations, and statements of Service procedures
affecting the rights and duties of taxpayers. * * *
* * * * * * *
(v) * * *
* * * * * * *
(d) Revenue Rulings published in the
Bulletin do not have the force and effect of
Treasury Department Regulations (including
Treasury decisions), but are published to provide
precedents to be used in the disposition of other
cases, and may be cited and relied upon for that
purpose. * * *
(e) Taxpayers generally may rely upon
Revenue Rulings published in the Bulletin in
determining the tax treatment of their own
transactions and need not request specific rulings
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