Centralized Authorization File

1. What is the Centralized Authorization File (CAF)?

2. To whom does the Chief Counsel of the IRS report?

3. You are researching a point of law and discover a private letter ruling that supports your position. May you use this authority in a memorandum of law to the IRS or in a court brief?

4. Distinguish a revenue ruling from a private letter ruling. May taxpayers be assured that the IRS will not challenge positions taken on tax returns that rely on these statements?

5. Is it always advisable to obtain a private letter ruling regarding a prospective transaction? What are some of the advantages and disadvantages of making such a request?

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