SECTION 7. EFFECTIVE DATE

.01 In general . This revenue procedure is effective January 27, 2014.

.02 Letter rulings will not be issued . Until January 1, 2015, for estates meeting the requirements of section 3.01(1)–(3) of this revenue procedure, the procedure described in section 4 must be used to obtain an extension of time under § 301.9100–3 to make a portability election under § 2010(c)(5)(A) in lieu of requesting a letter ruling under the provisions of § 301.9100–3. However, for requests for rulings pending on January 27, 2014, see section 7.03 of this revenue procedure.

.03 Transition rule for pending letter ruling requests . If an executor has filed a request for a letter ruling seeking an extension of time under § 301.9100–3 to make a portability election under § 2010(c)(5)(A), that letter ruling is pending in the national office on January 27, 2014, and the decedent’s estate is within the scope of this revenue procedure as described in section 3, the executor may rely on this revenue procedure, withdraw the letter ruling request and receive a refund of its user fee. However, the national office will process letter ruling requests pending on January 27, 2014, unless, prior to the earlier of March 10, 2014, or the issuance of the letter ruling, the executor notifies the national office that it will rely on this revenue procedure and withdraw its letter ruling request.