SECTION 9. HOW ARE

REQUESTS HANDLED?

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p. 67 .01 Issues under the jurisdiction of the Associate Chief Counsel (Domestic), the Associate Chief Counsel (Employee Benefits and Exempt Organizations), the Associate Chief Counsel (Enforcement Litigation), or the Associate Chief Counsel (International)

.02 Issues involving shipowners’ protection and indemnity associations and certain homeowners associations

p. 67 .01 Alcohol, tobacco, and firearms taxes

.02 Employee plans and exempt organizations

.03 Farmers’ cooperatives

p. 68 .01 A § 301.9100–1T request is a letter ruling request

.02 Statute of limitations

.03 Address to send a § 301.9100–1T request

.04 If the return is being examined or considered by an appeals office or a federal court, the taxpayer must notify the national office and the national office will notify the district director, appeals officer, or government counsel

p. 69 .01 District director or chief, appeals office, determines whether to request technical advice

.02 Taxpayer may ask that issue be referred for technical advice

p. 69 .01 Uniformity of position lacking

.02 When technical advice can be requested

.03 At the earliest possible stage

p. 69 .01 Statement of issues, facts, law, and arguments

.02 Statement identifying information to be deleted from public inspection

.03 Transmittal Form 4463, Request for Technical Advice

.04 Number of copies of request to be submitted

.05 Power of attorney

p. 71 .01 Taxpayer notified

.02 Conference offered

.03 If the taxpayer disagrees with the Service’s statement of facts

.04 If the Service disagrees with the taxpayer’s statement of facts

.05 If the taxpayer has not submitted the required deletions statement

.06 Section 6104 of the Internal Revenue Code (Applications for exemption and letter rulings issued to certain exempt organizations open to public inspection)

.07 Criminal or civil fraud cases

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