HAR § 18-231-19.5-03 — Written opinions

(a) The department’s decision as to what constitutes a written opinion shall be final and shall not be reviewable. (b) In each written opinion, the department shall: (1) State the relevant facts (as understood by the department), state the applicable provisions of law, and apply the law to the facts; (2) Segregate information as provided in section 18-231-19.5-04; (3) Prepare a notice of intention to disclose pursuant to section 18-231-19.5-05; and (4) Separately set forth the information to be indexed under section 18-231-19.5-11. (c) Written opinions may be incorporated into tax information releases or other guidance published by the department. (d) A written opinion may be modified or revoked by the department.