United States Department of The Treasury - Administrative Materials

Administrative Materials

As part of its administration of Federal tax, the Treasury issues a wide range of documents providing its interpretation of the Internal Revenue Code (IRC), which each document having a varying level of weight for which the tax payer may rely:

• Treasury Regulations reflect the Treasury's interpretation of the IRC, may be promulgated by the Secretary of the Treasury, and when final they have "force of law" status. Congress can sometimes carve out areas in which the Treasury can actually make, not just interpret, the rules.
• Revenue Rulings are issued under the same statutory authority as regulations, but generally are just a response to a taxpayer's question about their own tax liability. Published Revenue Rulings are released in the weekly Internal Revenue Bulletin and again in the semi-annual Cumulative Bulletin; they do not have the force or effect of regulations, but nonetheless may be cited and used by the public. Private Letter Rulings are also the IRS' response to a specific taxpayer's question regarding the tax consequences of a particular transaction and can be made public upon request. Although they may not be relied on by anyone other than the taxpayer that requested it, they are still useful for tax planning purposes.
• A Revenue Procedure is a statement of the Treasury's practice and procedures, and generally deals with a broad subject area.