SECTION 1. PURPOSE AND

NATURE OF CHANGES

.01 The purpose of this revenue procedure is to update Rev. Proc. 2001–3, 2001–1 I.R.B. 111, as amplified and modified by subsequent revenue procedures, by providing a revised list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions & Products), the Associate Chief Counsel (Income Tax & Accounting), the Associate Chief Counsel (Passthroughs & Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) relating to issues on which the Internal Revenue Service will not issue letter rulings or determination letters. For a list of areas under the jurisdiction of the Associate Chief Counsel (International) relating to international issues on which the Service will not issue letter rulings or determination letters, see Rev. Proc. 2002–7, this Bulletin. For a list of areas under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division relating to issues, plans or plan amendments on which the Service will not issue letter rulings and determination letters, see, respectively, section 8 of Rev. Proc. 2002–4, this Bulletin, and section 3.02 of Rev. Proc. 2002–6, this Bulletin.

.02 Changes. (1) Section 3.01(9) has been revised to reflect the changes made by Ann. 2001– 25, 2001–11 I.R.B. 895. (2) New section 3.01(10), which concerns § 115 and income of states, municipalities, etc., has been moved from old section 3.01(9).

(3) Section 3.01(30) has been revised to reflect changes made by Ann. 2001–25, 2001–11 I.R.B. 895. (4) New section 3.01(55) has been added, which concerns §§ 3121, 3306 and 3401, and determination of worker status for purposes of federal employment taxes and income tax withholding and Form SS–8.

(5) New section 3.02(9), which describes frivolous issues on which the Service generally will not rule, has been moved from old section 4.02(8) and amended to cross reference section 7.04 of Rev. Proc. 2002—1.

(6) Section 4.01(8) has been revised to reflect updated procedures contained in Rev. Proc. 96–16, 1996–1 C.B. 630.

(7) Section 4.01(11) has been revised to reflect that Rev. Rul. 2001–31, 2001–26 I.R.B. 1348, superseded Rev. Rul. 77–316 and modified Rev. Rul. 78–338. (8) New section 5.01 has been added, reflecting that Rev. Proc. 2001–30, 2001–19 I.R.B. 1163, deleted old section 5.01. (9) New section 5.06 has been added, reflecting that Rev. Proc. 2001–51, 2001–43 I.R.B. 369, deleted old section 5.06. (10) Section 6.02 has been revised to reflect that recent publications modified and amplified Rev. Proc. 99–49, 1999–2 C.B. 725.

(11) New section 6.06 has been added, which concerns requests from Qualified Master-Feeder Structures, as described in section 4.02 of Rev. Proc. 2001–36, 2001–23 I.R.B. 1326, for permission to aggregate built-in gains and losses from contributed qualified financial assets.