Letter rulings are the primary vehicle for responding to advisory opinion requests from outside the Department. A letter ruling is an official advisory opinion issued by the Department in response to a specific request from a specific taxpayer. The following statute authorizes the Department to promulgate rules regarding letter rulings:
Each agency shall provide by rule for the filing and prompt disposition of petitions for letter rulings as to the applicability of any statutory provision or of any rule or order of the agency, provided that nothing herein shall limit or impair the right of an agency to seek the opinion of the Attorney General of any question of law connected with the duties of the agency pursuant to Code Section 45-15-3 or any other applicable statutory or constitutional provision. Rulings disposing of petitions have the same status as agency decisions or orders in contested cases. O.C.G.A. § 50-13-11.
For more information about Letter Rulings and other written guidance, please refer to Administration Regulations.