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

Who does what
RoleWhat they do
AssistanceConsider narrowly defined preparation support after confirming the tool’s capability and permitted scope.
LawyerSet the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Checklist

  1. Open each relied-on authority independently. Confirm its existence, current status, proposition and any quotation or pinpoint reference.
  2. Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
  3. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  4. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

Related tasks

Related tools

Related jurisdictions