SECTION 7. REVOCATION OR

MODIFICATION

A letter ruling found to be in error or not in accord with the current views of the Service may be revoked or modified. If a letter ruling under this revenue procedure is revoked or modified, the revocation or modification applies to all open years under the statute of limitations unless the Service uses its discretionary authority under § 7805(b) to limit the retroactive effect of the revocation or modification. The criteria and procedures for revoking or modifying a letter ruling issued under this revenue procedure are the same as those provided in section 12 of Rev. Proc. 98–1. In addition, the procedures for requesting § 7805(b) relief, and the criteria for granting it, are the same as those provided in section 12.11 of Rev. Proc. 98–1.