A Private letter ruling is “[a] written statement issued to the taxpayer by the Internal Revenue Service in which interpretations of the tax law are made and applied to a specific set of facts. [The] [f]unction of the letter ruling, usually sought by the taxpayer in advance of a contemplated transaction, is to advise the taxpayer regarding the tax treatment he can expect from the I.R.S. in the circumstances specified by the ruling.” Black’s Law Dictionary, p. 1196 (6th ed. 1990)(West Publishing Company)(citing U.S. v. Wahlin, D.C.Wis., 384 F.Supp. 43, 47.) “. . . [U]nless the Secretary establishes otherwise by regulations, a “written determination” may not be used or cited as precedent by another taxpayer. Sec. 6110(j)(3); sec. 301.6110-7(b), Proced. & Admin. Regs. Written determinations include both private rulings and technical advice memoranda . . . . Sec. 301.6110-2(a), Proced. & Admin. Regs.” Lucky Stores, Inc. v. Commissioner, T.C. Memo. 1997-70 (1997)
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