SECTION 10. HOW DOES THE

NATIONAL OFFICE HANDLE LETTER RULING REQUESTS?

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p. 42

(2) To designate recipient of original or copy of letter ruling or determination letter

(3) To request a particular conclusion on a proposed transaction

(4) To request expedited handling

(5) To receive any document related to the letter ruling request by facsimile transmission (fax)

(6) To submit a request for a letter ruling by fax

(7) To request a conference

(8) To obtain the applicable user fee for substantially identical letter rulings or identical accounting method changes

.03 Address to send the request

(1) Requests for letter rulings

(2) Requests for determination letters

.04 Pending letter ruling requests

.05 When to attach letter ruling to return

.06 How to check on status of request

.07 Request may be withdrawn or national office may decline to issue letter ruling

.08 Compliance with Treasury Department Circular No. 230

.01 Checklists, guideline revenue procedures, and notices

.02 Safe harbor revenue procedures

.03 Automatic change revenue procedures

.01 Controls request and refers it to appropriate Associate Chief Counsel’s office or Assistant Chief Counsel’s office

.02 Branch representative contacts taxpayer within 21 days

.03 Notifies taxpayer if any issues have been referred to another branch or office

.04 Determines if transaction can be modified to obtain favorable letter ruling

.05 Is not bound by informal opinion expressed

.06 Tells taxpayer if request lacks essential information during initial contact

.07 Requires prompt submission of additional information requested after initial contact

January 7, 2002 4 2002–1 I.R.B.