SECTION 8. WHAT ARE THE

GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS?

p. 24 .01 Ordinarily not in certain areas because of factual nature of the problem

.02 Not on alternative plans or hypothetical situations

.03 Ordinarily not on part of an integrated transaction

.04 On constructive sales price under § 4216(b) or § 4218(c)

p. 25 .01 Certain information required in all requests

(1) Complete statement of facts and other information

(2) Copies of all contracts, wills, deeds, agreements, instruments, and other documents

(3) Analysis of material facts

(4) Statement regarding whether same issue is in an earlier return

(5) Statement regarding whether same or similar issue was previously ruled on or requested, or is currently pending

(6) Statement of supporting authorities

(7) Statement of contrary authorities

(8) Statement identifying pending legislation

(9) Statement identifying information to be deleted from copy of letter ruling or determination letter for public inspection

(10) Signature by taxpayer or authorized representative

(11) Authorized representatives

(12) Power of attorney and declaration of representative

(13) Penalties of perjury statement

(14) Number of copies of request to be submitted

(15) Sample format for a letter ruling request

(16) Checklist for letter ruling requests

.02 Additional information required in certain circumstances

(1) To request separate letter rulings for multiple issues in a single situation

(2) To designate recipient of original or copy of letter ruling or determination letter

(3) To request a particular conclusion on a proposed transaction

(4) To request expeditious handling

(5) To receive a letter ruling or submit a request for a letter ruling by facsimile transmission (fax)

(6) To request a conference

(7) To obtain the applicable user fee for substantially identical letter rulings or identical accounting method changes

.03 Address to send the request

(1) Requests for letter rulings

(2) Requests for determination letters

.04 Pending letter ruling requests

.05 When to attach letter ruling to return

.06 How to check on status of request

.07 Request may be withdrawn or national office may decline to issue letter ruling

.08 Compliance with Treasury Department Circular No. 230

13