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For tax attorneys

Test a ruling against your fact pattern.

Read what the IRS concluded, on which page and on what record, before a ruling reaches your memo.

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IRS Private Letter Ruling 202627005Released July 2, 2026 · Page 4

Sections 301.9100-1 through 301.9100-3 provide the standards the Commissioner will use to determine whether to grant an extension of time to make an election. 2

Based solely on the facts submitted and representations made, we conclude that X has satisfied the requirements of §§ 301.9100-1 and 301.9100-3 with respect to the QSub elections for Sub 1, Sub 2, Sub 3, Sub 4, Sub 5, and Sub 9. 1

Private letter ruling · Non-precedential

  1. 1 · Facts it relied onThe conclusion opens “Based solely on the facts submitted and representations made.” Set your client’s facts beside the ones the request represented.
  2. 2 · Standard applied§§ 301.9100-1 through 301.9100-3 are the standards for more time to make an election. Read them in their official text.
  3. LimitNon-precedential. The ruling resolves this taxpayer’s request, not yours.
Illustrative example. Page 4 of the public ruling, cropped to the passage. Text elsewhere on the page is not shown.

Illustrative situation

A close ruling is not yet a useful one.

Your client’s subsidiaries missed the deadline for their QSub elections, and a recent ruling looks close to your facts.

Virtus puts the conclusion on its page, beside the record it depends on, so the comparison is made against the document and not against a summary of it.

Three things to test before you lean on it.

  1. 01

    The facts

    The conclusion opens “Based solely on the facts submitted and representations made.” Read the request’s facts against yours before treating the result as a match.

  2. 02

    The standard

    The ruling applies §§ 301.9100-1 through 301.9100-3. Follow the reference to the official text when the rule itself matters.

  3. 03

    The limit

    A private letter ruling is nonprecedential. That label stays with the source as your research record grows.

Illustrative example

From a sentence to its page.

In an answer, each sentence carries a citation. Hover, focus or press it to read the cited passage with the ruling’s publisher, release date and nonprecedential label, then open the original.

The IRS concluded that the taxpayer met the requirements for more time under §§ 301.9100-1 and 301.9100-3 to make QSub elections it had missed for six subsidiaries.

VirtusSample workspace · illustrative data
A research answer with numbered citations, and beside it the cited ruling opened at its page with its status and the original PDF.
The same step in the sample workspace: a citation opened beside the answer, with the source’s page, status and original PDF in view.

Read next.

Bring a fact pattern.

See a question, its cited answer and the ruling page together.

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