SECTION 6. EFFECTIVE DATE

This revenue procedure is effective for all section 6166 elections filed on or after May 20, 2005. For any section 6166 election filed before May 20, 2005, an applicant may rely on section 4 of this revenue procedure to demonstrate that applicant has exhausted all administrative remedies within the Service.

DRAFTING INFORMATION

The principal author of this revenue procedure is Tracey B. Leibowitz of the Office of the Associate Chief Counsel, Procedure and Administration (Administrative Provisions and Judicial Practice Division). For further information regarding this revenue procedure, contact Ms. Leibowitz at (202) 622–4940 (not a toll-free call).

26 CFR 601.104: Collection functions. (Also Part I, §§ 6672; 301.6672.)

Rev. Proc. 2005–34