SECTION 5. EFFECTIVE DATE

.01 In General . This revenue procedure is effective August 9, 2004.

.02 Transition Rule for Pending Letter Ruling Requests . If an executor has filed a request for a letter ruling seeking relief to file a reverse QTIP election under § 301.9100–3 and that letter ruling request is pending in the national office on August 9, 2004, the executor may withdraw the letter ruling request and receive a refund of its user fee if prior to September 23, 2004, the executor notifies the national office that it will withdraw the letter ruling request. If the executor does not so notify the national office by September 23, 2004, the national office will process letter ruling requests pending on August 9, 2004, and will retain the user fee paid.