SECTION 20. EXHAUSTION OF

ADMINISTRATIVE REMEDIES

p. 240

p. 241

.01 Oral advice

.02 Conferences

.03 Determination letter based solely on administrative record

.04 Notice of final determination

.05 Issuance of the notice of final determination

.01 In general

.02 Steps for exhausting administrative remedies

.03 Applicant’s request for § 7805(b) relief

2002–1 I.R.B 207 January 7, 2002

.04 Interested parties

.05 Deemed exhaustion of administrative remedies

.06 Service must act on appeal

.07 Service must act on § 7805(b) request

.08 Effect of technical advice request

.01 Scope of reliance on determination letter

.02 Effect of determination letter on minor plan amendment

.03 Sections 13 and 14 of Rev. Proc. 2002–4 applicable

.04 Effect of subsequent publication of revenue ruling, etc.

.05 Determination letter does not apply to taxability issues