Private Letter Rulings

Private Letter Rulings (PLRs) are official responses from the IRS to a taxpayer’s request for guidance specific to his/her situation. It is a written statement which binds the IRS and the taxpayer only in the situation specified in the ruling. Since 1997 PLRs have been published on the IRS website for public viewing. This helps us in clarifying the intent of the law, but others cannot rely on the ruling for their own purposes. If you want to make 100% sure your SEPP meets the requirements of the law, you can request your own PLR. Some legal and tax professionals can support you through this process. The procedures and fees for submitting a PLR are published annually in the first revenue procedure of each calendar year (see Revenue Procedure 2019-1, Section 7. See Appendix A for a schedule of fees).


Below is a list of PLRs related to Section 72t distributions. Legalbitstream has an easy to use search tool for PLRs and other federal tax law research. Use the PLR number below to perform a search.

  • 201510060 – Extra payment due to financial institution error won’t trigger a SEPP IRA modification penalty
  • 201120011 – No COLA increases in a SEPP Plan under 72(t) or 72(q)
  • 201051025 – Switch from annual to monthly distributions OK and administrative error distribution makeup
  • 200925044 – Partial Transfer of SEPP treated as Distribution subject to 10% Penalty
  • 200720023 – Partial Transfer of SEPP treated as Distribution subject to 10% Penalty
  • 200616046 – Distribution Error Correction
  • 200616045 – 72(t) Annual Recalculation
  • 200601044 – Error in Distribution and Makeup
  • 200551033 – 72(t) Annual Recalculation
  • 200551032 – 72(t) Annual Recalculation
  • 200550039 – Defined Benefit Plans with Lump Sum and Periodic Distributions
  • 200544023 – 72(t) Annual Recalculation
  • 200532062 – 72(t) Annual Recalculation
  • 200503036 – Makeup Distribution and Good Documentation
  • 200437038 – Ceiling on 72(t) Interest Rates
  • 200442033 – Waiver of 60 Days to Comply with 2002-62
  • 200432021 – 72(t) Annual Recalculation
  • 200432024 – 72(t) Annual Recalculation
  • 200432023 – 72(t) Annual Recalculation
  • 200419031 – Switch to MD and roll excess distribution back to IRA within 60 days
  • 200313016 – Non-Qualified Tax-Deferred Annuities – 72(q) adopts 2002-62 – Beneficiary Distributions
  • 199909059 – Taxpayer terminates an existing SEPP, pays the 10% penalties and interest and starts a new SEPP with annual recalculation.