State Tax practitioners increasingly rely on letter rulings, technical bulletins, private guidance, and other administrative interpretations yet the procedural authority, transparency, and precedential weight of these tools vary dramatically across states. This session explores how agencies develop, publish, and apply letter rulings and internal guidance, along with the compliance, audit, and litigation risks that arise when taxpayers rely on them or defy them (or when states do not follow them). Panelists will examine trends post-Loper Bright, state-level "underground regulation" challenges, and the growing tension between public guidance and non-public directives used in audits. Attendees will leave with practical strategies for obtaining, evaluating, and challenging guidance in audits, refund claims, and litigation.
