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AmerGen tried to introduce PLRs from the IRS into evidence, but the court said no.
FORBES: No Virginia, You Can't Rely On IRS Rulings
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In the early 1980s, the U.S. Supreme Court even cited PLRs.
FORBES: No Virginia, You Can't Rely On IRS Rulings
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But there may be a new level of concern about just how warm and fuzzy tax advisers and clients feel even if we have a raft of PLRs similar to our facts.
FORBES: No Virginia, You Can't Rely On IRS Rulings
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PLRs are often the best available information.
FORBES: No Virginia, You Can't Rely On IRS Rulings
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You can thank Tax Analysts for breaking loose much of the otherwise secret IRS law, not only PLRs, but also Chief Counsel Advice, Technical Advice Memoranda, Field Service Advice, and many other IRS missives that shed light on what the IRS is doing and thinking.
FORBES: No Virginia, You Can't Rely On IRS Rulings