“Revenue Rulings, which address issues of substantive tax law, arise from various sources, including rulings to taxpayers, technical advice to district offices, studies undertaken by the IRS, court decisions, suggestions from practitioner groups, and so on. A revenue ruling is the Commissioner’s ‘official interpretation of the interpretation of the law’ and generally is binding on revenue agents and other IRS officials. Courts typically give revenue rulings far less weight than regulations, regarding them simply as the Commissioner’s view of the law. The IRS states that taxpayers generally may rely on published revenue rulings in determining the tax treatment of their own transaction that arise out of similar facts and circumstances.” Graetz, Federal Income Taxation: Principles and Policies, p. 73 (2nd ed. 1988) (Foundation Press).
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