SECTION 2. BACKGROUND

In the interest of sound tax administration, the IRS answers inquiries from individuals and organizations regarding their status for tax purposes and the tax effects of their acts or transactions. See Rev. Proc. 2022-1, 2022-1 IRB 1. There are, however, areas in which the IRS will not issue rulings or determination letters. The IRS incorporates these no-rule areas annually into the third revenue procedure of the year, currently Rev. Proc. 2022-3. Sections 3, 4, 5 and 6 of Rev. Proc. 2022-3 set forth lists of those areas in which rulings or determination letters (1) will not be issued, (2) will not ordinarily be issued, (3) will temporarily not be issued while

the area is under study, and (4) will not be issued because automatic approval procedures apply. In addition, section 2.01 of Rev. Proc. 2022-3 provides that additions or deletions to these lists may be made; changes will be published as they occur throughout the year and will be incorporated annually in a new revenue procedure published as the third revenue procedure of the year. The IRS has determined that it is in the interest of sound tax administration not to issue rulings on the transactions described in section 3 of this revenue procedure.