D.C. moves to revoke private rulings.

• Position: District of Columbia Office of Tax and Revenue

Does your company file its returns with the District of Columbia in reliance on a letter ruling issued by the D.C. Office of Tax and Revenue (OTR)? If so, you may be in for a surprise--the revocation of the ruling without notice. Such a dire result is the possible consequence of a July 1st OTR announcement--posted on its website--that taxpayers have until December 31, 2002, to send OTR a copy of any letter ruling they intend to rely on in filing a D.C. return after that date. Any letter rulings not received by the deadline are "generally revoked," according to the notice.

The motivation for, if not the mechanics of, the notice is understandable: OTR apparently wants to assess the number and scope of letter rulings issued by them and their predecessor agency, the Department of Finance and Revenue. Rather than work through its own records or develop a process that affords taxpayers time and specific notice in writing, however, OTR has put the onus on taxpayers to come forward or have their letter rulings revoked.

The notice states OTR will review all active rulings "in light of current tax law, the...