Vanderbilt Law Review


Saul C. Belz

First Page



The rulings program of the Internal Revenue Service was designed to meet the need for predictability of the tax consequences of any given financial transaction. Though the rulings program is not particularly important to the average taxpayer, it has become increasingly crucial both to the financial community and to the Service itself. As the tax laws become more complex, and tax risks become increasingly important to the success of business ventures, the need for confirmation before entering into a transaction is intensified. Thus parties to a transaction will generally request a ruling...

"whenever the answer is uncertain or when the transaction involves substantial sums of money, even when the uncertainty may not be very great. In such circumstances the availability of a ruling in advance of the transaction has become almost as important as the financing or the know-how involved."

This note will study the growth of the rulings program, the factors which must be weighed by the tax practitioner before requesting a ruling, and the amount of reliance which the taxpayer can safely place upon the Service's interpretation of the law as applied to his particular fact situation.