SECTION 20. WHAT IS THE

EFFECT OF THIS REVENUE PROCEDURE ON OTHER DOCUMENTS?

.07 Where the applicant has requested EP Determinations to seek technical advice on the applicability of § 7805(b) relief to a qualification issue under § 401(a) pursuant to a determination letter request, the applicant’s administrative remedies will not be considered exhausted until EP Technical has a reasonable time to act on the request for technical advice. ( See section 20 of Rev. Proc. 2002–6.)

.08 Where technical advice has been requested pursuant to an exempt organization’s request for § 7805(b) relief from the retroactive application of an adverse determination within the meaning of § 7428(a)(1), the exempt organization’s administrative remedies will not be considered exhausted, within the meaning of § 7428(b)(2), until EO Technical has a reasonable time to act on the request for technical advice.

Rev. Proc. 2001–5 is superseded.