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@BobKamman wrote:

Revenue rulings don’t come from Treasury, and don’t bind taxpayers or the courts. They merely state the position of the Internal Revenue Service as to how the law should apply to a particular set of stated facts.

That’s the message from the Finance Committee, whose chairman Senator Geezerley is sick at home with Covid-19. Nothing is going to get enacted soon. Maybe we will have some law by the July 15 filing date next year.

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Technically, it's the IRS that issues revenue rulings but we all know why it's always formally communicated that these are issued by the Treasury and the IRS.

Yeah, these are not binding to taxpayers and the courts (especially with your view that courts no longer give much deference to revenue rulings) but I wonder how many plan to take a contrary position, include a 8275 (or -R) for disclosure, and perhaps be prepared to fight that out in court.