SECTION 6. UNDER WHAT

CIRCUMSTANCES DO DISTRICT DIRECTORS ISSUE DETERMINATION LETTERS?

p. 18 .01 Issues under the jurisdiction of the Associate Chief Counsel (Domestic)

(1) Issues under the Assistant Chief Counsel (Corporate)

(2) Issues under the Assistant Chief Counsel (Financial Institutions and

Products)

(3) Issues under the Assistant Chief Counsel (Income Tax and Accounting)

(4) Issues under the Assistant Chief Counsel (Passthroughs and Special

Industries)

.02 Issues under the jurisdiction of the Associate Chief Counsel (Employee Benefits and Exempt Organizations)

.03 Issues under the jurisdiction of the Associate Chief Counsel (Enforcement Litigation)

.04 Issues under the jurisdiction of the Associate Chief Counsel (International)

p. 19 .01 Alcohol, tobacco, and firearms taxes

.02 Employee plans and exempt organizations

p. 19 .01 In income and gift tax matters

.02 Request for extension of time for making an election or for other relief under § 301.9100–1T of the temporary Procedure and Administration Regulations

.03 Determinations under § 999(d) of the Internal Revenue Code

.04 In matters involving § 367

.05 In estate tax matters

.06 In matters involving additional estate tax under § 2032A(c)

.07 In matters involving qualified domestic trusts under § 2056A

.08 In generation–skipping transfer tax matters

.09 In employment and excise tax matters

.10 In administrative provisions matters

.11 Generally not to business associations or groups

.12 Generally not to foreign governments

.13 Generally not on federal tax consequences of proposed legislation

.14 Issuance of a letter ruling before the issuance of a regulation or other published guidance

p. 23 .01 In income and gift tax matters

.02 In estate tax matters

.03 In generation-skipping transfer tax matters

.04 In employment and excise tax matters

.05 Circumstances under which determination letters are not issued by district director

.06 Requests concerning income, estate, or gift tax returns

.07 Attach a copy of determination letter to taxpayer’s return

.08 Review of determination letters

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