Sally Andrews calls you on the phone. She says that she has found a 2007 letter ruling that agrees with a position she wants to take on her tax return. She asks you about the precedential value of a letter ruling.

Indicate whether the following statements are "Correct" or "Incorrect" with regard to the precedential value of a letter ruling.

	A letter ruling is applicable only to the taxpayer it addresses. A letter ruling has no precedential authority over another taxpayer's situation.
	Letter rulings apply to all taxpayers with tax situations similar to the one the ruling addresses. Therefore, a letter ruling has precedential authority.
	Although a letter ruling is applicable only to the taxpayer it addresses, a ruling may be used as precedent for other taxpayers within the window of five years from the date the ruling was issued.

Complete the accountant's memo below for the office files.

TAX FILE MEMORANDUM

September 24, 2018

FROM: George Ames

SUBJECT: Telephone conversation with Sally Andrews on applicability of 2007 letter ruling

I told Sally Andrews that she (may/ may not) rely on the 2007 letter ruling that was issued. I stressed that a letter ruling (has no/ has) precedential value under 6110(k)(3).

I pointed out that a letter ruling indicates the position of the IRS on the specific fact pattern present as of the date of the letter ruling. As such, a letter ruling is (not primary/ primary) authority. However, under Notice 90-20, 1990-1 C.B. 328, a letter ruling (is/ is not) substantial authority for purposes of the accuracy-related penalty in 6662.