SECTION 19. WHAT IS THE

EFFECT OF THIS REV. PROC. ON OTHER DOCUMENTS?

p. 145 .01 Applies only to the taxpayer for whom technical advice was requested .02 Usually applies retroactively .03 Generally applied retroactively to modify or revoke prior technical

advice .04 Applies to continuing action or series of actions until specifically

withdrawn, modified or revoked .05 Applies to continuing action or series of actions until material facts

change .06 Not applied retroactively under certain conditions

p. 147 .01 Commissioner has discretionary authority under § 7805(b) of the Code .02 Taxpayer may request Commissioner to exercise authority .03 Form of request to limit retroactivity—before an examination .04 Form of request to limit retroactivity—during course of examination .05 Form of request to limit retroactivity—technical advice that does not

modify or revoke prior memorandum .06 Taxpayer’s right to a conference .07 Exhaustion of administrative remedies—employee plans determination

letter requests .08 Exhaustion of administrative remedies—exempt organization matters

p. 148