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.