The User Fee for Letter Ruling Requests Is Increased Again
At the beginning of each year the IRS releases a revenue procedure detailing how to go about requesting a private letter ruling, closing agreement or determination letter. This year’s revenue procedure is Rev. Proc. 2025-1, 2025-01 IRB 1 (December 30, 2024). The annual revenue procedure has gradually expanded and now takes up 117 pages in the Internal Revenue Bulletin. For someone not familiar with the process of seeking private letter rulings, complying with all the rules can seem a daunting task. To help comply, the revenue procedure contains a sample format for a request (Appendix B) and a checklist to be attached to the request to used to assure the request is complete (Appendix C).
There are few changes in this year’s version. The most significant change is to the user fee charged for ordinary letter rulings. The user fee is now $43,700, a 15% increase from the $38,000 charged last year. (There are reduced user fees for small taxpayers, for change in accounting method or period requests, and some other situations, but even the reduced fees have been increased. See, Appendix A for a full list of special rates.)
At one time private letter rulings provided a valuable tool for taxpayers (including cooperatives and their members) to use to obtain guidance with respect to the tax law.
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