SECTION 10. EFFECTIVE DATE

These procedures are generally effective with respect to adverse determinations made by the District on or after July 22, 1998, and in the case of a technical advice memorandum the public release of which occurred within one year prior to July 22, 1998, an appeal may be requested not later than 90 days after the publication of this revenue procedure in the Internal Revenue Bulletin.

DRAFTING INFORMATION

The principal authors of this revenue procedure are Thomas Carter Louthan, Director, Office of Alternative Dispute Resolution & Customer Service Programs, National Office Appeals; Sunita B. Lough, Senior Trial Attorney, Office of Assistant Chief Counsel (Field Service Division); and Joseph Grabowski, Analyst, Exempt Organizations Division. For further information regarding this revenue procedure, please contact Mr. Louthan at (202) 401-4098, Ms. Lough at (202) 6227870, or Mr. Grabowski at (202) 6227761 (not toll-free numbers).

.06 Closing agreement with the Dis- trict. The District will retain jurisdiction over the Bond Issue until the issuer has made a request to appeal the District’s adverse determination that interest on the Bond Issue is not excludable from gross income under § 103 of the Code and the agent’s file has been sent to Appeals in accordance with section 6. Prior to requesting an appeal, the issuer may enter into closing agreement discussions with the District and execute a closing agreement with respect to the Bond Issue. The District will generally prepare a closing agreement using the model closing agreement provided in Announcement 95–61, 1995–33 I.R.B. 25.