SECTION 6. UNDER WHAT p. 122 .01 In exempt organizations matters

CIRCUMSTANCES DOES THE NATIONAL .02 In employee plans matters OFFICE ISSUE LETTER RULINGS? .03 In qualifications matters

.04 Request for extension of time for making an election or for other relief

under § 301.9100–1 of the Procedure and Administration Regulations

.05 Issuance of a letter ruling before the issuance of a regulation or other pub lished guidance

.06 Issues in prior return

.07 Generally not to business associations or groups

.08 Generally not to foreign governments

.09 Generally not on federal tax consequences of proposed legislation

SECTION 7. UNDER WHAT p. 124 .01 Circumstances under which determination letters are issued by the key CIRCUMSTANCES DO district director KEY DISTRICT DIRECTORS ISSUE .02 In general DETERMINATION LETTERS? .03 In employee plans matters

.04 In exempt organizations matters

.05 Circumstances under which determination letters are not issued by the

key district director

.06 Requests involving returns already filed

.07 Attach a copy of determination letter to taxpayer’s return

.08 Review of determination letters

SECTION 8. UNDER WHAT p. 126 .01 Ordinarily not in certain areas because of factual nature of the problem CIRCUMSTANCES DOES THE SERVICE HAVE .02 Not on alternative plans or hypothetical situations DISCRETION TO ISSUE LETTER RULINGS AND .03 Ordinarily not on part of an integrated transaction DETERMINATION LETTERS?

.04 Not on partial terminations of employee plans

.05 Law requires letter ruling

.06 Issues under consideration by PBGC or DOL

.07 Cafeteria plans

.08 Determination letters

.09 Domicile in a foreign jurisdiction

January 5, 1998 114 1998–1 I.R.B.