SECTION 1. WHAT IS THE

PURPOSE OF THIS REVENUE PROCEDURE?

p. 179 .01 Oral advice

.02 Conferences

.03 Determination letter based solely on administrative record

.04 Notice of final determination

.05 Issuance of the notice of final determination

.06 Key district offices

p. 180 .01 In general

.02 Steps for exhausting administrative remedies

.03 Applicant’s request for § 7805(b) relief

.04 Interested parties

.05 Deemed exhaustion of administrative remedies

.06 Service must act on appeal

.07 Service must act on § 7805(b) request

.08 Effect of technical advice request

p. 181 .01 Scope of reliance on determination letter

.02 Effect of determination letter on minor plan amendment

.03 Sections 13 and 14 of Rev. Proc. 97–4 applicable

.04 Effect of subsequent publication of revenue ruling, etc.

.05 Determination letter does not apply to taxability issues

p. 182

p. 182

p. 182

156

Purpose of revenue procedure

Organization of revenue procedure