SECTION 3. BACKGROUND

.01 Legislation authorizing user fees. Section 10511 of the Revenue Act of 1987, P. L. 100–203, 101 Stat. 1330– 382, 1330–446, enacted December 22, 1987, directed the Secretary of the Treasury or delegate (the ‘‘Secretary’’) to establish a program requiring the payment of user fees for requests to the Service for letter rulings, opinion letters, determination letters, and similar requests. The fees charged under the program (1) were to vary according to categories or subcategories established by the Secretary; (2) were to be determined after taking into account the average time for, and difficulty of, complying with requests in each category and subcategory; and (3) were to be payable in advance. The Secretary was to provide for exemptions and reduced fees under the program as the Secretary determined to be appropriate, but the average fee applicable to each category must not be less than the amount specified in the statute. The fees were to apply to requests made on or after February 1, 1988, and before September

volume submitter plans .09 Notification letters issued by

key district offices with respect to regional prototype plans COMPLIANCE FEES AND

CORRECTION FEES .10 Compliance statements under

the Voluntary Compliance Resolution (VCR) program .11 Correction statements under

the Tax-Sheltered Annuity Voluntary Correction (TVC) program EXEMPT ORGANIZATIONS

USER FEES .12 Letter rulings .13 Determination letters and

requests for group exemption letters