Private Letter Rulings - using findings in a letter

[Judy rocks]

I'm writing a letter to the IRS and want to reference statements in a Private Letter ruling which help my case. What is the proper way to reference a Private Letter Ruling in a letter? Is it improper to cite it like I would a tax court case?

[taxea]

Private letter ruling are normally only for the specific incident. You could reference it when asking for a ruling for your client's situation.

[New York Enrolled Agent]

I'm writing a letter to the IRS and want to reference statements in a Private Letter ruling which help my case. What is the proper way to reference a Private Letter Ruling in a letter? Is it improper to cite it like I would a tax court case?

PLRs can not be used as precedent - but remember that is a legal term which Courts use as guide in future cases. The regulations at §1.6662-4(d) do state that PLRs are a source of authority. If your facts are aligned with the facts in a PLR, by all means use them in correspondence with the IRS.

I'm pasting a redacted snip from the IRM (highlights added)

4.10.7.2.10 (01-01-2006)
Private Letter Rulings and Technical Advice Memorandums

1.A Private Letter Ruling (PLR) represents the conclusion of the Service for an individual taxpayer. The application of a private letter ruling is confined to the specific case for which it was issued, unless the issue involved was specifically covered by statute, regulations, ruling, opinion, or decision published in the Internal Revenue Bulletin.
2....

3.A private letter ruling to a taxpayer or a technical advice memorandum to an area director, which relates to a particular case, should not be applied or relied upon as a precedent in the disposition of other cases. However, they provide insight with regard to the Service’s position on the law and serve as a guide.