SECTION 7. UNDER WHAT p. 19

CIRCUMSTANCES DOES THE SERVICE HAVE .01 Ordinarily not in certain areas because of factual nature of the problem DISCRETION TO ISSUE LETTER RULINGS AND .02 Not on alternative plans or hypothetical situations DETERMINATION LETTERS?

January 2, 2001 2 2001–1 I.R.B.

.03 Ordinarily not on part of an integrated transaction

.04 Ordinarily not on questions involving the validity of the federal income tax

or similar matters

.05 On constructive sales price under § 4216(b) or § 4218(c)

.06 Ordinarily not on which of two entities is the common law employer