SECTION 13. WHAT p. 142 .01 May be relied on subject to limitations

EFFECT WILL A LETTER RULING .02 Will not apply to another taxpayer HAVE?

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

January 5, 1998 116 1998–1 I.R.B.

.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 May be retroactively revoked or modified when transaction is completed

without reliance on the letter ruling

.09 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)