Advisory opinions are authorized by subdivision 24 of section 171 of the Tax Law and are addressed in detail in Part 2376 of this Title. Advisory opinions are binding upon the Division of Taxation and upon the Commissioner of Taxation and Finance only with respect to the person to whom such an opinion is rendered and only with respect to the set of facts stated in the opinion. The person to whom an advisory opinion is rendered is not bound by that opinion nor may any other person rely upon or be bound by such opinion. However, although advisory opinions do not have true precedential value, they are indicative of the commissioner's position concerning the applicability of statutory and regulatory provisions to specific sets of facts as of the date the opinion is issued or for the specific time period at issue in the opinion.