The Internal Revenue Service\u27s Mandatory Waiver of Confidentiality - The Practical and Constitutional Defects

This Comment focuses upon both the practical and constitutional defects present in the Internal Revenue Service\u27s proposed requirement of a mandatory waiver of confidentiality as a condition precedent to the issuing of a private letter ruling. The primary practical defect in the proposed amendments is that such a requirement may seriously undermine the present program of private rulings which plays an important part in both business planning and tax administration. The exact defects of the waiver requirement, while unknown, may prove costly to both the Service and the taxpayer