SECTION 15. REVOCATION

An opinion letter found to be in error or not in accord with the current views of the Service may be revoked. However, except in rare or unusual circumstances, such revocation will not be applied retroactively if the conditions set forth in sections 13 and 14 of Rev. Proc. 2009–4, 2009–1 I.R.B. 118 (disregarding references therein to §§ 7428 and 7476) are met. For this purpose, opinion letters will be given the same effect as rulings. Revocation may be effected by a notice to the prototype sponsor to which the letter was originally issued, or by a regulation, revenue ruling, or other statement published in the Internal Revenue Bulletin. The prototype sponsor should then notify each adopting eligible employer of the revocation as soon as possible. The content of the notification to each adopting eligible employer must explain how the revocation affects any reliance an adopting eligible employer has on the applicable opinion letter.