SECTION 14. UNDER WHAT

CIRCUMSTANCES ARE MATTERS REFERRED BETWEEN A KEY DISTRICT OFFICE AND THE NATIONAL OFFICE?

(3) Taxpayer steps in exhausting administrative remedies.

Consideration of relief under § 7805(b) will be included as one of the taxpayer’s steps in exhausting administrative remedies only if the taxpayer has requested such relief in the manner described in this revenue procedure. If the taxpayer does not complete the applicable steps, the taxpayer will not have exhausted the taxpayer’s administrative remedies as required by § 7428(b)(2) and § 7476(b)(3) and will, thus, be precluded from seeking a declaratory judgment under § 7428 or § 7476. Where the taxpayer has requested § 7805(b) relief, the taxpayer’s administrative remedies will not be considered exhausted until the national office has had a reasonable time to act upon the request.

Requests for determination letters .01 Requests for determination letters received by key district directors that, under the provisions of this revenue procedure, may not be issued by a key district office, will be forwarded to the national office for reply. The key district office will notify the taxpayer that the matter has been referred.

Key district directors will also refer to the national office any request for a determination letter that in their judgement should have the attention of the national office.

No-rule areas .02 If the request involves an issue on which the Service will not issue a letter ruling or determination letter, the request will not be forwarded to the national office. The key district office will notify the taxpayer that the Service will not issue a letter ruling or a determination letter on the issue. See section 8 of this revenue procedure for a description of no-rule areas.

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Requests for letter rulings .03 Requests for letter rulings received by the national office that, under section 6 of this revenue procedure, may not be acted upon by the national office will be forwarded to the key district office that has examination jurisdiction over the taxpayer’s return. The taxpayer will be notified of this action. If the request is on an issue or in an area of the type discussed in section 8 of this revenue procedure, and the Service decides not to issue a letter ruling or an information letter, the national office will notify the taxpayer and will then forward the request to the appropriate key district office for association with the related return.