SECTION 9. WHAT MUST BE

INCLUDED IN THE REQUEST?

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p. 135 .01 Issues under the jurisdiction of the Assistant Commissioner (Employee Plans and Exempt Organizations)

.02 Farmers’ cooperatives

.03 Basis for requesting technical advice

.04 Areas of mandatory technical advice

p. 136 .01 Matters (other than farmers’ cooperatives) under the jurisdiction of the Associate Chief Counsel (Domestic), the Associate Chief Counsel (Employee Benefits and Exempt Organizations), and the Associate Chief Counsel (International)

.02 Alcohol, tobacco, and firearms taxes

.03 Excise taxes

p. 136 .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 which will notify the key district director, appeals office or government counsel

p. 137 .01 Key district director or chief, appeals office determines whether to request technical advice

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

p. 138 .01 Uniformity of position lacking

.02 When technical advice can be requested

.03 At earliest possible stage

p. 138 .01 Statement of issues, facts, law, and arguments

.02 Statement pertaining to statute of limitations

.03 General provisions of §§ 6104 and 6110 of the Code

.04 Application of § 6104 of the Code

.05 Statement identifying information to be deleted from public inspection

.06 Transmittal Form 5565, Request for Technical Advice—EP/EO

.07 Number of copies of request to be submitted

.08 Power of attorney

.09 Case files

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