Revenue rulings are public administrative rulings by the Internal Revenue Service (IRS) in the United States Department of the Treasury of the United States federal government that apply the law to particular factual situations.
"[1] Revenue rulings are published "to promote correct and uniform application of the tax laws by Internal Revenue Service employees and to assist taxpayers in attaining maximum voluntary compliance by informing Service personnel and the public of National Office interpretations of the internal revenue laws, related statutes, treaties, regulations, and statements of Service procedures affecting the rights and duties of taxpayers.
"[2][3] A taxpayer may, for a fee, seek advice from the IRS on the proper tax treatment of a transaction.
Public administrative rulings are part of second-tier authorities and are subordinate to the Internal Revenue Code and other statutes, Treasury regulations, treaties, and court decisions.
They hold higher weight than third-tier authorities, such as legislative history and private letter rulings.