---
title: "Prepare a private letter ruling request"
url: "https://ailawframework.com/practice/taxation/draft-a-private-or-product-ruling-application/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-T1-R5-US"
practice_area: "Taxation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Prepare a private letter ruling request

> 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.

Canonical page: https://ailawframework.com/practice/taxation/draft-a-private-or-product-ruling-application/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Taxation](https://ailawframework.com/practice/taxation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| 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 | United States |
| Applies to | [Draft a private or product ruling application](https://ailawframework.com/practice/taxation/draft-a-private-or-product-ruling-application.md) |

## Checking plan

- What the AI does: 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.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Open Revenue Procedure 2026-1 itself before filing. The FAQ identifies it; it is not a substitute for section 7.
- A letter ruling is not a return position. The lawyer still decides whether the transaction proceeds.

## Sources

- [IRS: How to obtain a private letter ruling (Revenue Procedure 2026-1)](https://www.irs.gov/faqs/irs-procedures/code-revenue-procedures-regulations-letter-rulings/code-revenue-procedures-regulations-letter-rulings) (checked 2026-10-22)
- [IRS Office of Professional Responsibility, Issue 2026-19](https://www.irs.gov/pub/opr-taxpros/issue-number-2026-19-introductory-guidelines-for-responsible-ai-use-in-federal-tax-practice.pdf) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Client information request and facts declaration for a private ruling application or return position](https://ailawframework.com/precedents/taxation/client-information-request-and-facts-declaration-for-ruling.md) | Letter | Yellow | Letter asking a client for the facts and documents needed for a private ruling application (or a contentious return position), with a facts checklist, a supporting documents list, and the written… |

Signed-in accounts can read the full text of each one.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*