SECTION 1. PURPOSE

As required by § 3105 of the Internal Revenue Service Restructuring and Reform Act of 1998, P.L. 105–206 (the Act), this revenue procedure provides procedures for issuers to request an administrative appeal to the Office of Appeals (Appeals) of an adverse determination by an Employee Plans/Exempt Organizations Key District (the District) that the interest on their debt obligations (the Bond Issue) is not excludable from gross income under § 103 of the Internal Revenue Code. This revenue procedure also modifies the Internal Revenue Service’s existing procedures that the District must receive a technical advice memorandum from Assistant Chief Counsel (Financial Institutions & Products) that is unfavorable to the issuer prior to declaring that the interest on the Bond Issue is not excludable from gross income under § 103 of the Code, and makes other modifications to the examination process made appropriate by the Act.