The IRS issues various administrative authorities besides Treasury Regulations. These include Revenue Rulings, Revenue Procedures, and many nonprecedential authorities.
Know that Revenue Rulings are the IRS's application of the law to a specific set of completed facts. Often Revenue Rulings arise from the IRS National Office's further review of previously issued private letter rulings. In contrast to the general guidance provided in Treasury Regulations, Revenue Rulings provide issues, facts, law, and analysis on applying the law to a particular set of facts. Revenue Rulings are weaker authority than Treasury Regulations, merely representing the IRS's position on an issue. However, Revenue Rulings offer precedential value with the IRS for taxpayers with analogous fact patterns. An example Revenue Ruling is shown in Exhibit 5-7.
Understand that the citation to a Revenue Ruling does not reference the Code section that it addresses. However, for the researcher's convenience, a tax database, such as Checkpoint, will sometimes follow the Revenue Ruling citation with the relevant Code section. The researcher should remove the added Code section reference provided by the publisher when citing the Revenue Ruling.
Check the status of a Revenue Ruling by using a citator. For example, ...