For Letter Rulings and Similar Requests: Electronic Payment of User Fees Starts June 15

Friday, June 7, 2019

Beginning June 15, taxpayers requesting letter rulings, closing agreements and certain other rulings from the Internal Revenue Service will need to make user fee payments electronically using the federal government’s Pay.gov system.

Pay.gov allows people to pay for a variety of government services online using a credit card, debit card or via direct debit or electronic funds withdrawal from a checking or savings account. In the past, ruling requesters could only make required user fee payments by check or money order. During a two-month transition period, June 15 to Aug. 15, requesters can choose to make user fee payments either through Pay.gov or by check or money order. After Aug. 15, 2017, Pay.gov will become the only permissible payment method.

Rulings described in Revenue Procedure 2017-1 and sent to the Docket, Records and User Fee Branch of the Legal Processing Division of the Associate Chief Counsel (Procedure and Administration) (CC:PA:LPD:DRU) are affected by this change. These include private letter rulings, closing agreements, and rulings using Form 1128, 2553, 3115 or 8716. Determination letters are not affected because they are sent to other offices as described in the revenue procedure.

A letter ruling is a written determination issued to a taxpayer by IRS Chief Counsel in response to the taxpayer’s written inquiry, submitted prior to the filing of returns or reports required under federal law. In general, it concerns the requester's status for tax purposes or the tax effects of its acts or transactions. Letter rulings and other similar ruling requests interpret the tax laws and apply them to the taxpayer’s specific set of facts. User fees range from $200 to $28,300, depending upon the type of ruling being sought.

Pay.gov is used to accept payments only. The original, signed ruling request and supporting materials must still be submitted by mail or hand delivery to the IRS.

Back