Rev. Proc. 92-67, 1992-2 C.B. 429 (election under § 1278(b) to include market discount in
SECTION 17. WHAT
Internal Revenue Bulletin 2024-1 · 2026-10-03 edition · updated 2026-10-04 · United States
IS THE EFFECT OF THIS REVENUE PROCEDURE ON OTHER DOCUMENTS?
Section 7.02(4) has been amended to clarify that, except for a § 301.9100 request described in section 5.03 of this revenue procedure or for a request that includes a closing agreement with respect to an issue under the jurisdiction of the Associate Chief Counsel (Corporate) or another Associate Office, expedited handling under this section is not available for a letter ruling request that is solely or primarily under the jurisdiction of the Associate Chief Counsel (Corporate).
Section 7.04 has been amended to provide that request for determination letter under the jurisdiction of SB/SE or W&I may be submitted only by electronic facsimile.
Section 7.04(1)(b) has been deleted as users may no longer mail in requests for determination letters to SB/SE (with regards to estate and gift taxes, employment taxes, and excise taxes) or to W&I.
Section 8.02(2)(b) has been updated to direct users to section 5.05(1) of Rev. Proc. 2023-26, 2023-33 I.R.B. 486 for special rules and procedures applying to letter ruling requests under the jurisdiction of the Associate Chief Counsel (Corporate).
Section 8.05(1) has been updated to direct users to section 5.05(1) of Rev. Proc. 2023-26, 2023-33 I.R.B. 486 for special rules and procedures applying to letter ruling requests under the jurisdiction of the Associate Chief Counsel (Corporate).
Section 8.07 has been amended to clarify that a taxpayer submitting a fast-track processing of certain letter rulings that are solely or primarily under the jurisdiction of the Associate Chief Counsel (Corporate) must submit a proposed draft of the letter ruling at the time of the request pursuant to section 5.03(5) of Rev. Proc. 2023-26, 2023-33 I.R.B. 486.
Section 10.09 has been added to inform users that special rules and procedures apply to letter rulings requests that are primarily or solely under the jurisdiction of the Associate Chief Counsel (Corporate).
Section 15.08 has been amended to require the payment of the user fees described in that section through Pay.gov.
Appendix A(2) has been amended to reflect updated fees for Advance Pricing Agreement requests.
Appendix A(3)(e) has been amended to reflect an updated fee for requests for Foreign Insurance Excise Tax Waiver Agreements.
Appendix A(8) has been amended to reflect an updated fee for requests for tax treaty limitation of benefits determinations.
Editorial and clarifying changes have been made throughout.
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