SECTION 5. ON WHAT ISSUES

MUST WRITTEN GUIDANCE BE REQUESTED UNDER DIFFERENT PROCEDURES?

p. 132

p. 132

p. 132

p. 135

p. 135

2002–1 I.R.B 127 January 7, 2002

.01 In exempt organizations matters

.02 In employee plans matters

.03 In qualifications matters

.04 Request for extension of time for making an election or for other relief under § 301.9100–1 of the Procedure and Administration Regulations

.05 Issuance of a letter ruling before the issuance of a regulation or other published guidance

.06 Issues in prior return

.07 Generally not to business associations or groups

.08 Generally not to foreign governments

.09 Generally not on federal tax consequences of proposed legislation

.01 Circumstances under which determination letters are issued

.02 In general

.03 In employee plans matters

.04 In exempt organizations matters

.05 Circumstances under which determination letters are not issued

.06 Requests involving returns already filed

.07 Attach a copy of determination letter to taxpayer’s return

.08 Review of determination letters

.01 Ordinarily not in certain areas because of factual nature of the problem

.02 Not on alternative plans or hypothetical situations

.03 Ordinarily not on part of an integrated transaction

.04 Not on partial terminations of employee plans

.05 Law requires letter ruling

.06 Issues under consideration by PBGC or DOL

.07 Cafeteria plans

.08 Determination letters

.09 Domicile in a foreign jurisdiction

.10 Employee Stock Ownership Plans