TR-3 - How to Request a Ruling

To request a ruling, the taxpayer (or the taxpayer’s representative) should send a letter to Rulings Editor, Legal Office, 500 Deaderick Street, Nashville, TN 37242. The letter should include the following: 

  • The taxpayer’s (or representative’s) contact information, including mailing address and telephone number.
  • A check for the applicable fee.
  • A fully completed Power of Attorney, if required.
  • The taxpayer’s question or questions.
  • A description of all relevant facts.
  • A copy of any pertinent sample invoices, contracts, or the like (which may be provided in redacted form).
  • If appropriate, pictures of the equipment, products, or other items that are the subject of the ruling request.

The letter may also include the taxpayer’s analysis of the law; however, this is not required. The Department will contact the taxpayer to request any additional information or documentation that is required.

Rulings are issued in the Commissioner’s discretion. The Department generally declines to issue a ruling when the taxpayer requesting the ruling is under audit for the same tax, has requested an informal conference on the same issue, or has filed litigation on the same issue.

The Department may opt to decline to issue a ruling if it is determined that the taxpayer’s questions do not require an in-depth analysis of the law, if the Department has already published guidance on the same issue, or if the request is simply for confirmation of existing law. If the Department declines to issue a ruling, the taxpayer will be provided with an informal response and copies of any published guidance. In those cases, the ruling fee will be refunded to the taxpayer.

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