Letter Rulings

THESE REDACTED LETTER RULINGS WERE ISSUED BY THE OFFICE OF CHIEF COUNSEL, DEPARTMENT OF REVENUE IN RESPONSE TO SPECIFIC FACTS PROVIDED BY TAXPAYERS OR THEIR REPRESENTATIVES. IN SOME CASES, THE FACTS HAVE BEEN MODIFIED TO PROTECT THE IDENTITY OF THE REQUESTING TAXPAYER. THE PUBLICATION OF THESE LETTER RULINGS IS INTENDED TO PROVIDE INTERPRETIVE GUIDANCE TO THE GENERAL PUBLIC AND DOES NOT BIND THE DEPARTMENT TO ANY ENTITY OTHER THAN TO THE ORIGINAL TAXPAYER. STATUTORY OR REGULATORY CHANGES, JUDICIAL DECISIONS, OR DIFFERENT FACTS MAY MODIFY OR NEGATE A LETTER RULING. OTHERWISE, A LETTER RULING IS VALID FOR FIVE YEARS.