Private letter rulings, technical advice memoranda and field service advice memoranda involving tax-exempt bond issues

 

Private letter rulings (PLRs), technical advice memoranda (TAMs) and field service advice memoranda (FSAs) are taxpayer-specific rulings furnished by the IRS National Office in response to requests made by taxpayers and/or Internal Revenue Service officials.

It is important to note that, pursuant to 26 USC 6110(k)(3), such items cannot be used or cited as precedent.


Section 103

Interest on state and local bonds, political subdivision

Section 141

Private business use tests, government use, management contracts

Section 142

Assisted living facilities, exempt facility bond defined, local furnishing of electrical energy or gas, qualified residential rental project, solid waste disposal facility

Section 143

Qualified mortgage revenue bonds, residence requirements, average area purchase price

Section 144

Small issue bond defined, $10,000,000 limit, manufacturing facility

Section 145

Qualified 501(c)(3) bonds

Section 147

Public approval requirement

Section 148

Arbitrage, reasonable expectations - artifice or device, investment property, required rebate to the u.s., small government unit exception, penalty in lieu of rebate

Section 149

Advance refundings, bonds must be registered to be tax exempt, exceptions, federally guaranteed bond not exempt

Section 150

Definitions and special rules, general rules, change in use of facilities

Section 6431

Credit for qualified bonds allowed to issuer

Section 6700

Promoting abusive tax shelters

Section 7871

Indian tribal governments treated as states for certain purposes