§ 16-04 Contents.
RCNY § 16-04
A ruling will identify the person to whom it is addressed by name and address. It will contain (a) a recitation of the facts having a bearing on the issue sought to be resolved, (b) a discussion of the pertinent statutory provisions, regulations and other precedential material relied upon, (c) a description of the reasoning upon which the conclusions are based, and (d) a statement of conclusions. Such stated conclusions will give direct answers, where possible, to the specific questions raised by the taxpayer. The discussion contained in the ruling will be set forth with a sufficient degree of detail as to fairly apprise the taxpayer of the bases for the conclusions reached.
