SECTION 5. AREAS NOT COVERED

BY THIS REVENUE PROCEDURE

The granting of an extension of time to file an election under § 1.469–9(g) pursuant to this revenue procedure and the issuance of a notification described

in section 4.03 do not constitute an express or implied determination concerning whether the taxpayer satisfies the eligibility requirements under section 4.01 of this revenue procedure, whether the taxpayer satisfies the requirements under § 469(c)(7)(B), or whether the taxpayer materially participates in any activity.