In his Estate Planning and Philanthropy column, Conrad Teitell, a principal at Cummings & Lockwood, writes that if the federal tax consequences of a planned transaction aren't clear, prudence says get a favorable private letter ruling before proceeding. But each year, the IRS announces topics on which it won't rule. Does that mean that if you proceed without a ruling, that the hoped-for tax benefits will be denied? Not necessarily. But you have been warned that the IRS has some concerns.
The IRS's 'Won't Rule List' for 2012: Charitable Issues
New York Law Journal
April 24, 2012
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