- A. A private letter ruling is binding on the Comptroller for a period of 7 years from the date the private letter ruling is issued unless void, modified, or revoked in accordance with the provisions of Regulation .07 of this chapter.
- B. A private letter ruling is a determination of the Comptroller only as to the transaction that is the subject of the ruling.
- C. A petitioner is not bound by a private letter ruling.
- D. A petitioner’s failure to follow a private letter ruling may be considered in determining whether interest and penalty should be reduced or abated for reasonable cause in any subsequent challenge of an assessment or denial of a refund on the issue covered by the private letter ruling.
- E. A private letter ruling may be used as evidence of a petitioner’s knowledge or intent in a subsequent proceeding.
- F. The Comptroller may use information submitted in a petition for a private letter ruling for subsequent audit purposes.
Authority: State Government Article, §10-122(a); Tax-General Article, §§2-102, 2-103, and 13-1A-05; Annotated Code of Maryland
Effective date: January 8, 2024 (50:26 Md. R. 1131)