SERVICE EXPLAINS EXTENDED DEADLINE TO OBTAIN 'COMFORT RULINGS' IN SITUATIONS ADEQUATELY ADDRESSED BY PRECEDENT.

Rev. Proc. 89-51

SECTION 1. BACKGROUND

01 Rev. Proc. 89-34, 1989-20 I.R.B. 145, states that the Office of the Associate Chief Counsel (Technical) is discontinuing, except in extraordinary circumstances, the issuance of letter rulings on issues that are clearly and adequately addressed by the statute, regulations or other authority published in the Internal Revenue Bulletin.

02 Section 4 of Rev. Proc. 89-34 made the revenue procedure applicable to all ruling requests postmarked or, if not mailed, received 30 days or more after May 15, 1989.

03 Announcement 89-104, 1989-35 I.R.B. 19, states that the Service intends to postpone the effective date of Rev. Proc. 89-34, until February 5, 1990, and requests public comment with respect to modifications to, or additions to, the "comfort ruling" policy set forth in Rev. Proc. 89-34.

04 Announcement 89-105, 1989-35 I.R.B. 20, answers a number of commonly asked questions concerning Rev. Proc. 89-34, including how the procedures are to be administered.

SEC. 2. PURPOSE

In order to permit further consideration of the comments that the Service has received to Rev. Proc. 89-34 and to allow time to receive and consider the comments invited by Announcement 89-104 and Announcement 89-105, the Service is extending until February 5, 1990 the effective date of Rev. Proc. 89-34.

SEC. 3. EFFECTIVE DATE CHANGE

Section 4 of Rev. Proc. 89-34 is hereby modified to provide as follows: "This revenue procedure applies to all ruling requests postmarked or, if not mailed, received on or after February 5, 1990."

SEC. 4 EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 89-34 is modified.