SECTION 11. WHAT EFFECT WILL

A LETTER RULING HAVE?

(4) To request expeditious handling

(5) To receive a letter ruling or submit a request for a letter ruling by

facsimile transmission

(6) To request a conference

.03 Address to send the request

(1) Requests for letter rulings

(2) Requests for determination letters

.04 Pending letter ruling requests

.05 When to attach letter ruling to return

.06 How to check on status of request

.07 Request may be withdrawn or national office may decline to issue letter

ruling

.08 Compliance with Treasury Department Circular No. 230

p. 30 .01 Checklists and guideline revenue procedures

.02 Safe harbor revenue procedures

.03 Automatic change revenue procedures and notices

p. 34 .01 Controls request and refers it to appropriate Assistant Chief Counsel or

to the Office of Associate Chief Counsel (International)

.02 Branch representative contacts taxpayer within 21 days

.03 Notifies taxpayer if any issues have been referred to other branches

.04 Determines if transaction can be modified to obtain favorable letter ruling

.05 Is not bound by informal opinion expressed

.06 Tells taxpayer if request lacks essential information during initial contact

.07 Requires prompt submission of additional information requested after

initial contact

.08 Schedules a conference if requested by taxpayer

.09 Permits taxpayer one conference of right

.10 Disallows verbatim recording of conferences

.11 Makes tentative recommendations on substantive issues

.12 May offer additional conferences

.13 Requires written confirmation of information presented at conference

.14 May schedule pre-submission conference

.15 May, under limited circumstances, schedule a conference to be held by

telephone

.16 May request draft of proposed letter ruling near the completion of the

ruling process

.17 Advises the taxpayer of conclusions and, if the Service will rule

adversely, offers the taxpayer the opportunity to withdraw the letter ruling request

p. 39 .01 May be relied on subject to limitations

.02 Will not apply to another taxpayer

.03 Will be used by a district director in examining the taxpayer’s return

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