| Yes No N/A |
1. Does your request involve an issue under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division?
See section 5 of Rev. Proc. 2004-4, 2004-1 I.R.B. , for issues under the jurisdiction of other offices. (Hereafter, all
references are to Rev. Proc. 2004-4 unless otherwise noted.)
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| Yes No N/A |
2. If your request involves a matter on which letter rulings are not ordinarily issued, have you given compelling reasons
to justify the issuance of a private letter ruling? Before preparing your request, you may want to call the office responsible
for substantive interpretations of the principal Internal Revenue Code section on which you are seeking a letter ruling to
discuss the likelihood of an exception. The appropriate office to call for this information may be obtained by calling (202)
283-9660 (Employee Plans matters), or (202) 283-2300 (Exempt Organizations matters) (not toll-free calls).
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| Yes No N/A Page |
3. If the request involves an employee plans qualification matter under § 401(a), § 409, or § 4975(e)(7), have you demonstrated
that the request satisfies the three criteria in section 6.03 for a headquarters office ruling?
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| Yes No N/A Page |
4. If the request deals with a completed transaction, have you filed the return for the year in which the transaction was
completed? See sections 6.01 and 6.02.
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| Yes No |
5. Are you requesting a letter ruling on a hypothetical situation or question? See section 8.02. |
| Yes No |
6. Are you requesting a letter ruling on alternative plans of a proposed transaction? See section 8.02. |
| Yes No |
7. Are you requesting the letter ruling for only part of an integrated transaction? See section 8.03. |
| Yes No |
8. Have you submitted another letter ruling request for the transaction covered by this request? |
| Yes No |
9. Are you requesting the letter ruling for a business, trade, industrial association, or similar group concerning the application
of tax law to its members? See section 6.07.
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| Yes No Pages |
10. Have you included a complete statement of all the facts relevant to the transaction? See section 9.02(1). |
| Yes No N/A |
11. Have you submitted with the request true copies of all wills, deeds, plan documents, and other documents relevant to
the transaction, and labelled and attached them in alphabetical sequence? See section 9.02(2).
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| Yes No Page |
12. Have you included, rather than merely by reference, all material facts from the documents in the request? Are they accompanied
by an analysis of their bearing on the issues that specifies the document provisions that apply? See section 9.02(3).
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| Yes No Page |
13. Have you included the required statement regarding whether the same issue in the letter ruling request is in an earlier
return of the taxpayer or in a return for any year of a related taxpayer? See section 9.02(4).
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| Yes No Page |
14. Have you included the required statement regarding whether the Service previously ruled on the same or similar issue
for the taxpayer, a related taxpayer, or a predecessor? See section 9.02(5).
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| Yes No Page |
15. Have you included the required statement regarding whether the taxpayer, a related taxpayer, a predecessor, or any
representatives previously submitted the same or similar issue but withdrew it before the letter ruling was issued? See
section 9.02(5).
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| Yes No Page |
16. Have you included the required statement regarding whether the law in connection with the request is uncertain and
whether the issue is adequately addressed by relevant authorities? See section 9.02(6).
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| Yes No Pages |
17. Have you included the required statement of relevant authorities in support of your views? See section 9.02(6). |
| Yes No N/A Pages |
18. Does your request discuss the implications of any legislation, tax treaties, court decisions, regulations, notices,
revenue rulings, or revenue procedures you determined to be contrary to the position advanced? See section 9.02(7), which
states that taxpayers are encouraged to inform the Service of such authorities.
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| Yes No N/A Page |
19. If you determined that there are no contrary authorities, have you included a statement to this effect in your request?
See section 9.02(7).
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| Yes No N/A Page___ |
20. Have you included in your request a statement identifying any pending legislation that may affect the proposed transaction?
See section 9.02(8).
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| Yes No |
21. Is the request accompanied by the deletions statement required by § 6110? See section 9.02(9). |
| Yes No N/A Page___ |
22. Have you (or your authorized representative) signed and dated the request? See section 9.02(10). |
| Yes No N/A |
23. If the request is signed by your representative, or if your representative will appear before the Service in connection
with the request, is the request accompanied by a properly prepared and signed power of attorney with the signatory’s name
typed or printed? See section 9.02(12).
|
| Yes No N/A Page___ |
24. Have you included, signed and dated, the penalties of perjury statement in the form required by section 9.02(13)? |
| Yes No N/A |
25. Have you included the correct user fee with the request and made your check or money order payable to the United States
Treasury? See section 9.02(14) and Rev. Proc. 2004-8, page , this Bulletin, for the correct amount and additional information
on user fees.
|
| Yes No N/A |
26. Are you submitting your request in duplicate if necessary? See section 9.02(15). |
| Yes No N/A Pages |
27. If you are requesting separate letter rulings on different issues involving one factual situation, have you included
a statement to that effect in each request? See section 9.03(1).
|
| Yes No N/A |
28. If you want the original of the ruling to be sent to a representative, does the power of attorney contain a statement
to that effect? See section 9.03(2).
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| Yes No N/A |
29. If you do not want a copy of the letter ruling to be sent to any representative, does the power of attorney contain
a statement to that effect? See section 9.03(2).
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| Yes No N/A Page |
30. If you have more than one representative, have you designated whether the second representative listed on the power
of attorney is to receive a copy of the letter ruling? See section 9.03(2).
|
| Yes No N/A |
31. If you want your letter ruling request to be processed ahead of the regular order or by a specific date, have you requested
expedited handling in the form required by section 9.03(3) and stated a compelling need for such action in the request?
|
| Yes No N/A Page |
32. If you are requesting that a copy of the letter ruling be issued by facsimile (fax) transmission, have you included
a statement containing a waiver of any disclosure violations resulting from the fax transmission? See section 9.03(4).
|
| Yes No N/A Page |
33. If you want to have a conference on the issues involved in the request, have you included a request for conference
in the ruling request? See section 9.03(5).
|
| Yes No N/A |
34. If your request is covered by any of the guideline revenue procedures or other special requirements listed in section
10 of Rev. Proc. 2004-4, have you complied with all of the requirements of the applicable revenue procedure?
|
| Yes No N/A Page |
35. If you are requesting relief under § 7805(b) (regarding retroactive effect), have you complied with all of the requirements
in section 13.09?
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| Yes No N/A |
36. Have you addressed your request to the appropriate office listed in section 9.04? Improperly addressed requests may
be delayed (sometimes for over a week) in reaching the appropriate office for initial processing.
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