(1) In this section, “department” means the department of revenue. (2) Upon receipt of a request, in the form prescribed by the department, from a person who requests a ruling about facts relating to a tax that the department administers, the department may issue a private letter ruling. Rulings under this section: (a) May be published if the department decides to do so. (b) May be edited by the requester as to types of information specified by the department, if that editing is submitted to the department before the deadline that the department establishes and if the department approves the editing. (c) Do not bind the requester. (d) May not be appealed. (e) Do not preclude application for a declaratory ruling under s. 227.41. (3) Any person who receives a ruling under this section shall attach a copy of it to all of that person’s tax returns to which it is relevant. (4) Rulings under this section and all information related to them are subject to the confidentiality provisions for the tax relevant to the request, except that if a ruling has been edited under sub. (2) (b), or the deadline for editing set by the department has expired, and if the ruling has been published by the department, the published rulings are not subject to those confidentiality provisions. (5) The department’s decision not to issue, or not to publish, a ruling under this section may not be appealed.
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