Part II of Form 2553 under § 301.9100–3 (except as provided in paragraph
SECTION 17. WHAT IS THE p. 97
Internal Revenue Bulletin 2000-1 · 2026-10-03 edition · updated 2026-10-04 · United States
EFFECT OF TECHNICAL ADVICE? .01 Applies only to the taxpayer for whom technical advice was requested
.02 Usually applies retroactively
.03 Generally applied retroactively to modify or revoke prior technical advice
.04 Applies to continuing action or series of actions until specifically with drawn, modified, or revoked
January 3, 2000 76 2000–1 I.R.B.
.05 Applies to continuing action or series of actions until material facts change
.06 Does not apply retroactively under certain conditions
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