SECTION 4. PROCEDURE

.01 A request for consent to revoke an election made under § 83(b) must be made under the procedures for requesting a letter ruling. See Rev. Proc. 2006–1, 2006–1 I.R.B. 1, or its successor.

.02 In addition to a complete description of the facts and the other information and documents required under section 7.01 of Rev. Proc. 2006–1, or its successor, the request must contain: the date the § 83(b) election was made; a copy of the § 83(b) election; a description of the mistake of fact as to the underlying transaction; and the date on which the mistake of fact first became known to the person making the election.

.03 If the request to revoke an election under § 83(b) is being made on or before the due date for making the election, this fact must be included in the request for revocation.