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Introduction

SECTION 2. BACKGROUND AND

Internal Revenue Bulletin 2006-1 · 2026-10-03 edition · updated 2026-10-04 · United States

SCOPE OF APPLICATION

.01 Background. Whenever appropriate in the interest of sound tax administration, it is the policy of the Service to answer inquiries of individuals and organizations regarding their status for tax purposes and the tax effects of their acts or transactions, prior to the filing of returns or reports that are required by the revenue laws.

There are, however, certain areas in which, because of the inherently factual nature of the problems involved, or for other reasons, the Service will not issue rulings or determination letters. These areas are set forth in four sections of this revenue procedure. Section 3 reflects those areas in which rulings and determinations will not be issued. Section 4 sets forth those areas in which they will not ordinarily be issued. “Not ordinarily” means that unique and compelling

Sec. 1 January 3, 2006 122 2006–1 I.R.B.

letter will state that the Service did not consider, and no opinion is expressed upon, that issue. In appropriate cases the Service may decline to issue rulings or determinations on such larger transactions due to the relevance of the no-rule issue, despite the taxpayer’s representation.

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▸Contents — Internal Revenue Bulletin 2006-1
Internal Revenue Bulletin 2006-1

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