SECTION 3. APPLICATION — Internal Revenue Bulletin 2006-48

.01 If a chapter 12 plan proponent is authorized by the bankruptcy court to request a determination of the income tax effects of a proposed plan, a written request must be filed with the Centralized Insolvency Operation, Post Office Box 21126, Philadelphia, PA 19114 (marked, “Request for Determination of Tax Effects of Chapter 12 Plan”).

.02 A request is processable only if it contains the information specified in section 7.01, paragraphs (1) through (10), of Revenue Procedure 2006–1, as updated annually, including a copy of the proposed chapter 12 plan and a copy of the bankruptcy court order allowing the proponent to make the request. The request must be signed by the proponent with the following declaration, “Under penalties of perjury, I declare that I have examined this

request, including the accompanying documents, and, to the best of my knowledge and belief, this request contains all relevant facts relating to the request, and such facts are true, accurate, and complete.” The Service will not treat the request as having been made until it receives the information described in this section. The Service will acknowledge in writing the date it has received the request with the information required by this section. Additional information may be requested during the consideration of the request.

Within 270 days from receipt of a processable application, the Examination Function will notify the plan proponent of the determination. Unless the court declares otherwise pursuant to 11 U.S.C. § 1231(b), a field office examining the taxpayer’s return will follow the determination if: (1) a copy of the determination is attached to the tax return to which it relates, (2), the determination is properly reflected in the return, (3) the representations upon which the determination was made

26 CFR 601.602: Tax forms and instructions. (Also Part I, §§ 1, 23, 24, 25A, 25B, 32, 42, 59, 62, 63, 68, 132, 135, 137, 146, 148, 151, 170, 179, 213, 219, 220, 221, 223, 408A, 512, 513, 685, 877, 911, 2032A, 2503, 2523, 4161, 4261, 6033, 6039F, 6323, 6334, 6601, 7430, 7702B; 1.148–5.)

Rev. Proc. 2006–53

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