Unformatted text preview: Revenue Ruling would provide protection to Tom. 2. Answer: You should advise J.P. to withdraw his Private Letter Ruling request. Even though it is not certain that the IRS will issue an unfavorable ruling, because it appears that J.P. will not receive a favorable ruling, J.P. runs the risk of having to attach an unfavorable ruling to his return. By withdrawing his Private letter Ruling request, J.P. may still enter the transaction, if he feels comfortable doing so, and not have to attach a ruling to his return....
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- Spring '10
- Taxation in the United States, Private letter ruling