| CIRCLE ONE |
ITEM |
| 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. 2012-4,
2012-1 I.R.B. , for issues under the jurisdiction of other offices.
(Hereafter, all references are to Rev. Proc. 2012-4 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) 283-0289 (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 8.03.
|
| Yes No |
6. Are you requesting a letter
ruling on alternative plans of a proposed transaction? See section
8.03.
|
| Yes No |
7. Are you requesting the letter
ruling for only part of an integrated transaction? See section 8.04.
|
| 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.
|
| 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 labeled and attached them
in alphabetical sequence? See section 9.02(2).
|
| 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).
|
| 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).
|
| 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).
|
| 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).
|
| 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).
|
| 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).
|
| 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).
|
| 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).
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| Yes No N/A Page |
24. Have you included, signed
and dated, the penalties of perjury statement in Page 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.
2012-8, page , this Bulletin for the correct amount and additional
information on user fees.
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| 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 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 |
29. 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 |
30. 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 |
31. 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 |
32. If your request is covered
by any of the guideline revenue procedures or other special requirements
listed in section 10 of Rev. Proc. 2012-4, have you complied with
all of the requirements of the applicable revenue procedure?
|
| Yes No N/A Page |
33. If you are requesting relief
under § 7805(b) (regarding retroactive effect), have you
complied with all of the requirements in section 13.09?
|
| Yes No N/A |
34. 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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