1. What is the Centralized Authorization File (CAF)? 2. To whom does the Chief Counsel of the IRS report?

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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