SECTION 8. REQUESTING

SUPPLEMENTAL LETTER RULINGS

If the material facts underlying a letter ruling issued under this revenue procedure change after the letter ruling is issued, the taxpayer may request that the Service modify or supplement the letter ruling. However, the request cannot be made after the transaction, as revised, is completed, and the time for filing returns, with extensions, for all years covering the transaction has expired. For example, if the Service issues a ruling allowing the taxpayer to deduct costs incurred under one method of land remediation, and the taxpayer later decides to use a different method of land remediation, the taxpayer may request a supplemental letter ruling addressing the new method. However, the taxpayer

Rev. Proc. 97–1

TABLE OF CONTENTS

may not request the supplemental letter ruling after the land remediation under the new method is completed and the time for filing its returns, with extensions, for all transaction years has passed. The request must comply with the requirements of sections 4.01 or 4.02 of this revenue procedure, whichever applies.