Prepare a private letter ruling request
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- Assemble the ruling request from the facts the lawyer has settled, and list each item Revenue Procedure 2026-1 requires so the lawyer can tick it off.
- What the lawyer must review
- The IRS states that the procedures and user fees for a letter ruling are published in the first revenue procedure of the year, and for 2026 that is Revenue Procedure 2026-1. The request, including the user fee, follows section 7 of that procedure, and Appendix A of that procedure is the fee schedule. Open section 7 and Appendix A and complete the request from them. Do not send a request that still contains a generated fact or a generated citation you have not checked. OPR Issue 2026-19: verify facts, citations and calculations before submission to the IRS.
- Written for / version
- United States versionUSCth
Who does what
| Role | What they do |
|---|---|
| Assistance | Consider narrowly defined preparation support after confirming the tool’s capability and permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Open each relied-on authority independently. Confirm its existence, current status, proposition and any quotation or pinpoint reference.
- Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.