SECTION 12. WHAT EFFECT

WILL A LETTER RULING HAVE?

p. 33 .01 Checklists and guideline revenue procedures and notices

.02 Safe harbor revenue procedures

.03 Automatic change revenue procedures and notices

p. 38 .01 Controls request and refers it to appropriate Assistant Chief Counsel or to the Office of Associate Chief Counsel (International)

.02 Branch representative contacts taxpayer within 21 days

.03 Notifies taxpayer if any issues have been referred to another branch or office

.04 Determines if transaction can be modified to obtain favorable letter ruling

.05 Is not bound by informal opinion expressed

.06 Tells taxpayer if request lacks essential information during initial contact

.07 Requires prompt submission of additional information requested after initial contact

.08 Near the completion of the ruling process, advises the taxpayer of conclusions and, if the Service will rule adversely, offers the taxpayer the opportunity to withdraw the letter ruling request

.09 May request draft of proposed letter ruling near the completion of the ruling process

.10 Issues separate letter rulings for substantially identical letter rulings and generally issues a single letter ruling for identical accounting method changes

.11 Sends copy of letter ruling to district director

p. 41 .01 Schedules a conference if requested by taxpayer

.02 Permits taxpayer one conference of right

.03 Disallows verbatim recording of conferences

.04 Makes tentative recommendations on substantive issues

.05 May offer additional conferences

.06 Requires written confirmation of information presented at conference

.07 May schedule a pre-submission conference

.08 Under limited circumstances, may schedule a conference to be held by telephone

p. 42 .01 May be relied on subject to limitations

.02 Will not apply to another taxpayer

.03 Will be used by a 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 Generally not retroactively revoked or modified if related to sale or lease subject to excise tax

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