According to the IRS website, a PLR (private letter ruling) cannot be relied on as legal precedent by other taxpayers. So, the answer is likely incorrect without further proof of legal precedent. The original person asking the question should probably obtain their own PLR.
IRS website about PLRs: <a rel="nofollow" target="_blank" href="
https://www.irs.gov/tax-exempt-bonds/teb-private-letter-ruling-some-basic-concepts">https://www.irs....>
