Rev. Proc. 2004-47, 2004-2, C.B. 169, provides an alternative method for certain…

obtain an extension of time to make a late reverse qualified terminable interest property election under § 2652(a)(3). Rev. Proc. 2004-47 also informs taxpayers who are denied relief or who are outside the scope of the revenue procedure of the information necessary to obtain a letter ruling.

Rev. Proc. 87-28, 1987-1 C.B. 770 (treating references to former § 162(k) as if they were references to § 4980B).