SECTION 12. WHAT EFFECT

WILL A LETTER RULING HAVE?

p. 46

p. 49

.08 Near the completion of the ruling process, advises the taxpayer of conclusions and, if the Service will rule adversely, offers the taxpayer the opportunity to withdraw the letter ruling request

.09 May request draft of proposed letter ruling near the completion of the ruling process

.10 Issues separate letter rulings for substantially identical letter rulings and generally issues a single letter ruling for identical accounting method changes

.11 Sends a copy of the letter ruling to appropriate Service official

.01 Schedules a conference if requested by taxpayer

.02 Permits taxpayer one conference of right

.03 Disallows verbatim recording of conferences

.04 Makes tentative recommendations on substantive issues

.05 May offer additional conferences

.06 Requires written confirmation of information presented at conference

.07 May schedule a pre-submission conference

.08 Under limited circumstances, may schedule a conference to be held by telephone

.01 May be relied on subject to limitations

.02 Will not apply to another taxpayer

.03 Will be used by a director in examining the taxpayer’s return

.04 May be revoked or modified if found to be in error

.05 Not generally revoked or modified retroactively

.06 Retroactive effect of revocation or modification applied to a particular transaction

.07 Retroactive effect of revocation or modification applied to a continuing action or series of actions

.08 Generally not retroactively revoked or modified if related to sale or lease subject to excise tax

.09 May be retroactively revoked or modified when transaction is entered into before the issuance of the letter ruling

.10 May be retroactively revoked or modified when transaction is entered into after a change in material facts

.11 Taxpayer may request that retroactivity be limited

(1) Request for relief under § 7805(b) must be made in required format

2002–1 I.R.B 5 January 7, 2002

(2) Taxpayer may request a conference on application of § 7805(b)

.01 Has same effect as a letter ruling

.02 Taxpayer may request that retroactive effect of revocation or modification be limited

(1) Request for relief under § 7805(b) must be made in required format

(2) Taxpayer may request a conference on application of § 7805(b)

.01 Requests for determination letters

.02 No-rule areas

.03 Requests for letter rulings

.01 Legislation authorizing user fees

.02 Requests to which a user fee applies

.03 Requests to which a user fee does not apply

.04 Exemptions from the user fee requirements

.05 Fee schedule

.06 Applicable user fee for a request involving multiple offices, fee categories, issues, transactions, or entities

.07 Applicable user fee for substantially identical letter rulings or identical accounting method changes

.08 Method of payment

.09 Effect of nonpayment or payment of incorrect amount

.10 Refunds of user fee

.11 Request for reconsideration of user fee

.01 Will be made available to the public

.02 Deletions made under the Freedom of Information Act

.03 Effect of information letters