We have a client with a very similar situation as that described in a 1993 PLR and would like to contact the applicant. Is there a way to find out the identity?

The Internal Revenue Service won't disclose the identity of the ruling applicant.

However, the IRS will respond to a Freedom of Information Act request for the IRS file on consideration of a ruling request. You get the file with the correspondence and any documents the applicant submitted. Upon a FOIA request, all materials will be redacted to get rid of any information described in the taxpayer/applicant's proposed statement of deletions [see Rev Proc 2000-1] and, even if not requested by the applicant, any information that would have the effect of revealing the identity of the taxpayer.

The taxpayer and its attorney or representative will get a notice that a FOIA request was made, but they won't be told the identity of the FOIA requestor.



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