SECTION 14. UNDER WHAT

CIRCUMSTANCES ARE MATTERS REFERRED BETWEEN A FIELD OFFICE AND THE NATIONAL OFFICE?

Requests for determination letters .01 Requests for determination letters received by directors that, under the provisions of this revenue procedure, may not be issued by a field office, will be forwarded to the national office for reply. The field office will notify the taxpayer that the matter has been referred.

Directors will also refer to the national office any request for a determination letter that in their judgment should have the attention of the national office.

No-rule areas .02 If the request involves an issue on which the Service will not issue a letter ruling or determination letter, the request will not be forwarded to the national office. The field office will notify the taxpayer that the Service will not issue a letter ruling or a determination letter on the issue. See section 7 of this revenue procedure for a description of no-rule areas.

Requests for letter rulings .03 Requests for letter rulings received by the national office that, under section 5 of this revenue procedure, may not be acted upon by the national office will be forwarded to the field office that has examination jurisdiction over the taxpayer’s return. The taxpayer will be notified of this action. If the request is on an issue or in an area of the type discussed in section 7 of this revenue procedure and the Service decides not to issue a letter ruling or an information letter, the national office will notify the taxpayer and will then forward the request to the appropriate field office for association with the related return.