LII adds IRS written determinations (private-letter rulings)
We’ve added a new feature especially designed for tax types. We’ve linked the IRS Written Determinations ( a/k/a the private-letter rulings) to the sections of the Code to which they apply. For example, go to http://www.law.cornell.edu/
uscode/text/26/79 ; just below the yellow how-current-is-this banner you’ll see a tab labelled “IRS rulings”. Click on it to get to the PLRs. There are, by the way, over 58,000 PLRs distributed over around 850 sections of the Code. They are by no means evenly distributed — some sections have only one associated PLR; others have thousands.
A few caveats: the feature is still in beta test, and we’re going to need a month or so to be completely sure that updates are running smoothly. According to the IRS, updates run “every Friday morning” at their end, so we’re running ours early on Saturday morning (it appears from this week’s events that they don’t actually appear on the site until late Friday night). They take about an hour to process once they’re available. As you will see in the explanatory text that comes along with the listing inside the tab, there are some problems in the data as we receive it, mostly in the date fields.
At some point in the future, we’ll be adding full-text search that will cover the PLRs for any particular section. This will be particularly useful in sections like 501, where there are well over 10,000 applicable PLRs. Not sure when that will happen, but it’s on the list.
By the way, we’d love to talk with anyone out there who is familiar with the IRS Uniform Issue List Code system. We infer from what they say on the site that the issue codes are assigned in order to issues within a particular section; they seem to function almost like “accession numbers” for issues, rather than as a cross-cutting indexing system where the numbers relate to the same thing in each section. Which is kind of too bad if it’s true.
As always, we’re eager for feedback of any kind related to this or any other aspect of the LII site.
[ A special tip of the LII hat to Bill Allen, Cornell’s UBIT guru, who suggested the feature. ]