SECTION 3. BACKGROUND

.01 Legislation authorizing user fees. Section 10511 of the Revenue Act of 1987, Pub. L. 100-203, 101 Stat. 1330382, 1330-446, enacted December 22, 1987, directed the Secretary of the Treasury or his delegate (the “Secretary”) to establish a program requiring the payment of user fees for requests to the Service for letter rulings, opinion letters, determination letters, and similar requests. The fees charged under the program (1) were to vary according to categories or subcategories established by the Secretary; (2) were to be determined after taking into account the average time for, and diffi

January 4, 1999 230 1999–1 I.R.B.

various revenue procedures that require payment of a user fee, a voluntary compliance fee under the VCR program or the SVP, a voluntary correction fee under the TVC program, or an administrative scrutiny determination user fee are described in the appendix to this revenue procedure.