SECTION 5. EFFECTIVE DATES

.01 General Effective Date . Except as provided by section 5.02 of this revenue procedure, this revenue procedure is effective [INSERT IRB PUBLICATION DATE], the date of publication of this revenue procedure in the Internal Revenue Bulletin.

.02 Transition Rule for Pending PLR Requests .

(1) Requirement to notify IRS . If a taxpayer has a request for a PLR regarding a non-identical governing provision that is postmarked or, if not mailed, received

by the IRS on or before [INSERT DATE 1 DAY AFTER IRB PUBLICATION DATE], one day after the date of publication of this revenue procedure in the Internal Revenue Bulletin (pending ruling request), within 45 calendar days after that date, the taxpayer must notify the Associate Chief Counsel (Passthroughs and Special Industries) of its decision to either:

(a) Rely on this revenue procedure, withdraw the pending PLR request, and receive a refund of the associated user fee; or

(b) Continue to pursue the pending PLR request.

(2) Failure to notify IRS . If a taxpayer described in section 5.02(1) of this revenue procedure does not satisfy the notification requirement under that section, the taxpayer is deemed to choose to continue to pursue the pending PLR request.