List the three types of IRS written determinations and briefly explain the differences

Answer 1

The three types of IRS written determinations are Private Letter Rulings, Technical Advice Memoranda, and Determination Letters. Private Letter Rulings are issued by the National Office of the IRS in response to a taxpayer's request for the IRS's position on a specified tax issue, usually a proposed transaction. Technical Advice Memoranda are issued by the IRS National Office in response to a request by an IRS agent when a question arises during an audit. Thus, Technical Advice Memoranda deal with completed transactions. Determination Letters are similar to Private Letter Rulings, but they are issued by a local IRS office such as a District Director, to a taxpayer, generally on the tax treatment of a completed transaction.