SECTION 12. WHAT p. 47

EFFECT WILLA LETTER RULING HAVE? .01 May be relied on subject to limitations

.02 Will not apply to another taxpayer

.03 Will be used by a district director in examining the taxpayer’s return

.04 May be revoked or modified if found to be in error

.05 Not generally revoked or modified retroactively

.06 Retroactive effect of revocation or modification applied to a particular

transaction

.07 Retroactive effect of revocation or modification applied to a continuing

action or series of actions

.08 Generally not retroactively revoked or modified if related to sale or lease

subject to excise tax

.09 May be retroactively revoked or modified when transaction is entered into

before the issuance of the letter ruling

.10 May be retroactively revoked or modified when transaction is entered into

after a change in material facts

.11 Taxpayer may request that retroactivity be limited

(1) Request for relief under § 7805(b) must be made in required format

(2) Taxpayer may request a conference on application of § 7805(b)

1998–1 I.R.B. 11 January 5, 1998