SECTION 1. WHAT IS THE

PURPOSE OF THIS REVENUE PROCEDURE?

Description of terms used in this revenue procedure

p. 59

p. 61

This revenue procedure explains how the Internal Revenue Service gives guidance to taxpayers on issues under the jurisdiction of the Associate Chief Counsel (Domestic), the Associate Chief Counsel (Employee Benefits and Exempt Organizations), the Associate Chief Counsel (Enforcement Litigation), and the Associate Chief Counsel (International). It explains the kinds of guidance and the manner in which guidance is requested by taxpayers and provided by the Service. A sample format of a request for a letter ruling is provided in Appendix B.

For purposes of this revenue procedure—

(1) any reference to district director or district office includes their respective offices or, when appropriate, the Assistant Commissioner (International);

(2) the term ‘‘taxpayer’’ includes all persons subject to any provision of the Internal Revenue Code (including issuers of § 103 obligations) and, when appropriate, their representatives; and

(3) the term ‘‘national office’’ refers to the Office of Associate Chief Counsel (Domestic), the Office of Associate Chief Counsel (Employee Benefits and Exempt Organizations), the Office of Associate Chief Counsel (Enforcement Litigation), or the Office of Associate Chief Counsel (International), as appropriate.

Updated annually The revenue procedure is updated annually as the first revenue procedure of the year, but may be modified or amplified during the year.