SECTION 6. REQUEST FOR

COMMENTS

The Service requests comments concerning this revenue procedure and the standard to be applied in determining whether fuel produced from coal is a solid synthetic fuel. In particular, the Service requests comments on whether significant chemical change is an appropriate test and, if so, what constitutes such a change. The Service also requests comments on whether, in the case of solid fuels other than coke, additional or alternative tests are needed. Comments are specifically requested with respect to the following: (1) should the § 29 credit for solid synthetic fuel under § 29(c)(1)(C) be allowed only where domestic energy production is increased; (2) under what circumstances should the § 29 credit for solid synthetic fuel under § 29(c)(1)(C) be allowed with respect to fuel produced from waste coal and coal fines; and (3) must a solid synthetic fuel have a market value that is significantly greater than the market value of the coal and any additives from which it is produced.

To facilitate speedy resolution, the Service requests that comments be submitted by November 27, 2000. An original and eight copies of written comments should be mailed to:

Internal Revenue Service Attn: CC:MSP:R (Rev. Proc. 2000–47) Room 5228 (PSI:Br6) PO Box 7604 Ben Franklin Station Washington, DC 20044

26 CFR 601.201: Rulings and determination letters. (Also Part I, section 29.)

Rev. Proc. 2000–47