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Author: TheBadger Big red star, 1000 posts Old School Fool Add to my Favorite Fools Ignore this person (you won't see their posts anymore) Number: of 121572  
Subject: PLR's Setting Precedent Date: 7/25/1999 10:49 AM
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I fully aware that the IRS has always said & courts have upheld that PLR's are in fact private and only pertain to the facts & circumstances of the filing taxpayer.

However, there are many sections of the code where NO rules, regulations, GCM's, notices, TCM's exist; but a material number of PLR's do exist from which it is possible to extract "theory of interpretation".

In this circumstance, is anyone aware of a case or ruling that does allow what I will call "extraction of principle" from one or more PLR's to be done & further to be binding on the IRS? Or mybe it would be better said, a case or ruling that prohibits (probably on the basis of "public policy") that the IRS can not take a position on a taxpayer in direct contradiction of the "principles" of previuosly issued PLR's.



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