SECTION 13. WHAT EFFECT

WILL A DETERMINATION LETTER HAVE?

.05 Pending letter ruling requests .06 When to attach letter ruling to return .07 How to check on status of request .08 Request may be withdrawn or the national office may decline to issue

letter ruling .09 Compliance with Treasury Department Circular No. 230

p. 114 .01 In general .02 Exempt Organizations .03 Employee Plans

p. 115 .01 In general .02 Is not bound by informal opinion expressed .03 Tells taxpayer if request lacks essential information during initial

p. 120 .01 Has same effect as a letter ruling .02 Taxpayer may request that retroactive effect of revocation or

modification be limited

contact .04 Requires prompt submission of additional information requested after

initial contact .05 Schedules a conference if requested by taxpayer .06 Permits taxpayer one conference of right .07 Disallows verbatim recording of conferences .08 Makes tentative recommendations on substantive issues .09 May offer additional conferences .10 Requires written confirmation of information presented at conference .11 May schedule pre-submission conference .12 May, under limited circumstances, schedule a conference to be held by

telephone .13 May request draft of proposed letter ruling near the completion of the

ruling process .14 Advises the taxpayer of final conclusions and, if the Service will rule

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

p. 118 .01 May be relied on subject to limitations .02 Will not apply to another taxpayer .03 Will be used by a key district director in examining the taxpayer’s

return .04 May be revoked or modified if found to be in error .05 Not generally revoked or modified retroactively .06 Retroactive effect of revocation or modification applied to a particular

transaction .07 Retroactive effect of revocation or modification applied to a continuing

action or series of actions .08 May be retroactively revoked or modified when transaction is

completed without reliance on the letter ruling .09 Taxpayer may request that retroactivity be limited

(1) Request for relief under § 7805(b) must be made in required

format (2) Taxpayer may request a conference on application of § 7805(b)

(1) Request for relief under § 7805(b) must be made in required

format (2) Taxpayer may request a conference on application of § 7805(b) (3) Taxpayer steps in exhausting administrative remedies

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