Permalink Submitted by Alan Spross on Mon, 2011-08-01 23:12
Rough guess would be several months starting with the IRS receipt of a properly filed request and their acknowledgement to accept the request. This varies by the subject of the PLR and amount of research required as well as if the IRS will expedite the request. A simple 60 day rollover extension would be expected to take less than the average time because there are so many of these annually.
Check with your local CPA organization and get a referral to someone who does alot of this type of work and they may be able to give you a better ballpark guess on the length of time as well as their legal fees which are in addition to the IRS filing fees. I imagine some of these times are aggravated by missing info in the filing before the IRS will even agree to rule on a specific request.
Permalink Submitted by Bruce Steiner on Tue, 2011-08-02 03:41
It varies depending on the situation. If all goes well, about 4 to 6 months, though it can take longer. Often after the IRS reviews the ruling request, they ask for additional information. If there’s a particular reason you need the ruling quickly, sometimes you can get expedited treatment.
Alan: the tax/estates departments of many law firms should be familiar with the ruling process. However, it’s unlikely that any one lawyer would submit a large number of ruling requests. You would only apply for a ruling for a transaction if you would only do the transaction if you received a favorable ruling.
It would be helpful to know what is involved here.
Permalink Submitted by Giles Sorrells on Tue, 2011-08-02 14:44
Thanks for the responses. Do any of you know any reliable IRS phone numbers/contacts that can tell my lawyer the status of my application? It was sent mid-may and the $3000 check was cashed May27.My lawyer has tried all the numbers in the private ruling publications and either no one answers the phone or he gets a rookie who doesn’t even know what a private letter is!
Permalink Submitted by Alan Spross on Mon, 2011-08-01 23:12
Rough guess would be several months starting with the IRS receipt of a properly filed request and their acknowledgement to accept the request. This varies by the subject of the PLR and amount of research required as well as if the IRS will expedite the request. A simple 60 day rollover extension would be expected to take less than the average time because there are so many of these annually.
Check with your local CPA organization and get a referral to someone who does alot of this type of work and they may be able to give you a better ballpark guess on the length of time as well as their legal fees which are in addition to the IRS filing fees. I imagine some of these times are aggravated by missing info in the filing before the IRS will even agree to rule on a specific request.
Permalink Submitted by Bruce Steiner on Tue, 2011-08-02 03:41
It varies depending on the situation. If all goes well, about 4 to 6 months, though it can take longer. Often after the IRS reviews the ruling request, they ask for additional information. If there’s a particular reason you need the ruling quickly, sometimes you can get expedited treatment.
Alan: the tax/estates departments of many law firms should be familiar with the ruling process. However, it’s unlikely that any one lawyer would submit a large number of ruling requests. You would only apply for a ruling for a transaction if you would only do the transaction if you received a favorable ruling.
It would be helpful to know what is involved here.
Permalink Submitted by Giles Sorrells on Tue, 2011-08-02 14:44
Thanks for the responses. Do any of you know any reliable IRS phone numbers/contacts that can tell my lawyer the status of my application? It was sent mid-may and the $3000 check was cashed May27.My lawyer has tried all the numbers in the private ruling publications and either no one answers the phone or he gets a rookie who doesn’t even know what a private letter is!