SECTION 1. PURPOSE

This revenue procedure provides special procedures for requesting written guidance from the Internal Revenue Service on the tax treatment under §§ 162 and 263 of the Internal Revenue Code of environmental cleanup costs incurred in transactions that span several years, including future years and prior years (whether or not under examination). These special procedures are available for letter ruling requests submitted during the two-year period beginning on month, day, year . The purpose of this revenue procedure is to facilitate the resolution of issues involving the capitalization or deduction of environmental cleanup costs for both prior and future years of a single environmental cleanup transaction.