SECTION 8. WHAT ARE THE p. 23

GENERAL INSTRUCTIONS .01 Certain information required in all requests FOR REQUESTING LETTER RULINGS AND (1) Complete statement of facts and other information DETERMINATION LETTERS?

(2) Copies of all contracts, wills, deeds, agreements, instruments, other docu

ments, and foreign laws

(3) Analysis of material facts

(4) Statement regarding whether same issue is in an earlier return

(5) Statement regarding whether same or similar issue was previously ruled

on or requested, or is currently pending

(6) Statement of supporting authorities

(7) Statement of contrary authorities

(8) Statement identifying pending legislation

(9) Statement identifying information to be deleted from copy of letter ruling

or determination letter for public inspection

(10) Signature by taxpayer or authorized representative

(11) Authorized representatives

(12) Power of attorney and declaration of representative

(13) Penalties of perjury statement

(14) Number of copies of request to be submitted

(15) Sample format for a letter ruling request

(16) Checklist for letter ruling requests

.02 Additional information required in certain circumstances

(1) To request separate letter rulings for multiple issues in a single situation

(2) To designate recipient of original or copy of letter ruling or determination

letter

(3) To request a particular conclusion on a proposed transaction

(4) To request expeditious handling

(5) To receive a letter ruling or submit a request for a letter ruling by facsim ile transmission (fax)

(6) To request a conference

January 4, 1999 8 1999–1 I.R.B.

(7) To obtain the applicable user fee for substantially identical letter rulings

or identical accounting method changes

.03 Address to send the request

(1) Requests for letter rulings

(2) Requests for determination letters

.04 Pending letter ruling requests

.05 When to attach letter ruling to return

.06 How to check on status of request

.07 Request may be withdrawn or national office may decline to issue letter rul ing

.08 Compliance with Treasury Department Circular No. 230