| Purpose/Objective of Rule |
I find that the immediate adoption of amendments to this rule is necessary to respond to recent difficulty caused by the withdrawal of a private letter ruling issued by the Department and disseminated by the taxpayer to others. Notwithstanding that, by law, private letter rulings are limited in their applicability to the taxpayer requesting guidance from the Department, it is clear that taxpayers have relied to their detriment on the guidance and analysis in the private letter ruling. |