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Introduction›Part III. Administrative, Procedural, and Miscellaneous

SECTION 2. BACKGROUND AND

Internal Revenue Bulletin 1997-1 · 2026-10-03 edition · updated 2026-10-04 · United States

SCOPE OF APPLICATION

.01 Background Whenever appropriate in the interest of sound tax administration, it is the policy of the Service to answer inquiries of individuals and organizations regarding their status for tax purposes and the tax effects of their acts or transactions, prior to the filing of returns or reports that are required by the revenue laws.

There are, however, certain areas in which, because of the inherently factual nature of the problems involved, or for other reasons, the Service will not issue advance rulings or determination letters. These areas are set forth in four sections of this revenue procedure. Section 3 reflects those areas in which advance rulings and determinations will not be issued. Section 4 sets forth those areas in which they will not ordinarily be issued. ‘‘Not ordinarily’’ means that unique and compelling reasons must be demonstrated to justify the issuance of a ruling or determination letter. Those sections reflect a number of specific ques

26 CFR 601.201: Rulings and determination let- ters.

Rev. Proc. 97–3

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▸Contents — Internal Revenue Bulletin 1997-1
Internal Revenue Bulletin 1997-1

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