IRS Corrects Revised Procedures For Issuing Letter Rulings.

Part IV. Items of General Interest

This document contains corrections to Revenue Procedure 2011-1, 2011-1 I.R.B. 1, which contained two outdated references to user fee amounts.

Correction 1:

Appendix A(A)(5)(a) incorrectly read:

"Substantially identical letter rulings requested (other than changes in methods of accounting requested on Form 3115)

Situations in which a taxpayer requests substantially identical letter rulings for multiple entities with a common member or sponsor, or for multiple members of a common entity, or for two or more identical trusts or for multiple beneficiaries of a trust or a trust divided into identical subtrusts or for husband and wife making split gifts, for each additional letter ruling request after the $11,500 fee or reduced fee, as applicable, has been paid for the first letter ruling request

NOTE: Each entity or member that is entitled to the user fee under paragraph (A)(5)(a) of this appendix, that receives relief under § 301.9100-3 (for example, an extension of time to file an election) will be charged a separate user fee for the letter ruling request on the underlying issue.

NOTE: The fee charged for the first letter ruling is the highest fee applicable to any of the entities. If any of the additional entities would meet the income test for the $625 fee, then that fee applies."

Appendix A(A)(5)(a) should have read:

"Substantially identical letter rulings requested (other than changes in methods of accounting requested on Form 3115)

Situations in which a taxpayer requests substantially identical letter rulings for multiple entities with a common member or sponsor, or for multiple members of a common entity, or for two or more identical trusts or for multiple beneficiaries of a trust or a trust divided into identical subtrusts or for husband and wife making split gifts, for each additional letter ruling request after the $14,000 fee or reduced fee, as applicable, has been paid for the first letter ruling request

NOTE: Each entity or member that is entitled to the user fee under paragraph (A)(5)(a) of this appendix, that receives relief under § 301.9100-3 (for example, an extension of time to file an election) will be charged a separate user fee for the letter ruling request on the underlying issue.

NOTE: The fee charged for the first letter ruling is the highest fee applicable to any of the entities. If any of the additional entities would meet the income test for the $625 fee, then that fee applies."

Correction 2:

Appendix A(A)(5)(b) read:

"Identical change in method of accounting requested on a single Form 3115, Application for Change in Accounting Method, for a situation (but not a combination of situations) described in section 15.07(4) .

A situation (but not a combination of situations) described in section 15.07(4) for each additional applicant seeking the identical change in method of accounting on the same Form 3115 after the $3,800 fee or $625 reduced fee, as applicable, has been paid for the first applicant."

Appendix A(A)(5)(b) should have read:

"Identical change in method of accounting requested on a single Form 3115, Application for Change in Accounting Method, for a situation (but not a combination of situations) described in section 15.07( 4).

A situation (but not a combination of situations) described in section 15.07(4) for each additional applicant seeking the identical change in method of accounting on the same Form 3115 after the $4,200 fee or $625 reduced fee, as applicable, has been paid for the first applicant."

The principal author of this announcement is Kimberly S. Barsa of the Office of Associate Chief Counsel (Procedure & Administration). For further information regarding this announcement, contact Kimberly S. Barsa at (202) 622-3620 (not a toll-free call).