Environmental Lawyer BLog

If you have a security interest in a partnership or LLC interest, you probably perfected that security interest by filing a UCC financing statement against the debtor. And if you were the first to file against most partnership or LLC interests, you had first priority upon filing. However, you would probably be shocked to find out that a party who subsequently obtains a security interest can jump your priority.

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If you are considering requesting a private letter ruling from the IRS, there is a process which can save you significant time and expense. Prior to submitting an extensive private ruling request, you can first file a request for a pre-submission conference. This procedure allows the IRS to evaluate a brief overview of the issue, after which the IRS will recommend that you (a) schedule a conference with IRS attorneys to discuss the matter further, (b) submit a full-fledged private ruling request, or (c) not move forward with a private ruling request. You will then be able to assess the strength of your request without incurring the legal and administrative fees associated with a full-fledged letter ruling request.

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