SECTION 18. HOW p. 177

MAY RETROACTIVE EFFECT BE LIMITED? .01 Commissioner has discretionary authority under § 7805(b) of the Code

.02 Taxpayer may request Commissioner to exercise authority

.03 Form of request to limit retroactivity—before an examination

.04 Form of request to limit retroactivity—during course of examination

.05 Form of request to limit retroactivity—technical advice that does not modify or revoke prior memorandum

.06 Taxpayer’s right to a conference

.07 Exhaustion of administrative remedies—employee plans determination letter requests

.08 Exhaustion of administrative remedies — exempt organization matters

January 5, 1998 158 1998–1 I.R.B.