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.
The opinions expressed in these rulings are based upon the information contained in the requests and are limited to the specific transactions and persons in question. Rulings have no precedential value except to the person to whom the ruling was issued and then only for the specific transaction addressed in the ruling. Should the circumstances regarding a transaction change, or differ materially from those represented, then a ruling may become invalid. In addition, please be advised that subsequent statutory or administrative rule changes or judicial interpretations of the statutes and rules upon which this advice is based may subject similar future transactions to a different tax treatment than that expressed in these rulings.