A question only the Service can settle. A ruling request in its own format.

Describe the facts and the rulings you want. CitedTax drafts the request in the order the revenue procedure requires, argues each ruling from the Code and the regulations, checks the no-rule list, and for a missed election sets out the reasonable-action and no-prejudice case under Reg. 301.9100-3.

Create your firm account Read a sample ruling request

At a glance

Cost: 1 credit ($25)
You provide: the parties, the facts or proposed transaction, the rulings sought, and for a missed election the election, its due date and why it was missed
You receive: a ruling request in your firm's name following the annual revenue procedure, with the analysis cited, the required statements and the penalties-of-perjury declaration
Turnaround: about thirty minutes

Credits never expire. A request that fails on our side returns its credits automatically.

What you get

Three things to count on.

The format the Service expects

Facts, rulings requested, analysis, the required statements, the deletions statement, the user fee and the declaration, in order.

Each ruling argued

The provision, its conditions and the facts that meet them, through the citation gate, with contrary authority noted.

9100 relief built in

Where an election was missed, the reasonable-action and good-faith facts and the absence of prejudice to the government, with the affidavits the regulation requires.

A worked example

A section 754 election omitted from a partnership return

The request asks for an extension of time under Reg. 301.9100-3 to make the election for 2024, shows the partnership relied on a tax professional and acted as if the election were in effect, and states why the government is not prejudiced.

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