IRS Pre-Submission Conferences
If you are considering requesting a private letter ruling from the IRS, there is a process which can save you significant time and expense. Prior to submitting an extensive private ruling request, you can first file a request for a pre-submission conference. This procedure allows the IRS to evaluate a brief overview of the issue, after which the IRS will recommend that you (a) schedule a conference with IRS attorneys to discuss the matter further, (b) submit a full-fledged private ruling request, or (c) not move forward with a private ruling request. You will then be able to assess the strength of your request without incurring the legal and administrative fees associated with a full-fledged letter ruling request.
A pre-submission conference may be requested in writing or by telephone, though the IRS often recommends that the taxpayer submit a short letter (1-2 pages) which briefly explains the primary issue -- that way it can be assigned to the appropriate branch at the IRS. The request should also identify the Associate Office expected to have jurisdiction over the request for a letter ruling.
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