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SERVICE FORMALLY ANNOUNCES REPLACEMENT OF 'COMFORT RULING' POLICY WITH ALTERNATIVE SOURCES OF GUIDANCE.


Rev. Proc. 90-42; 1990-2 C.B. 420

DATED
DOCUMENT ATTRIBUTES
  • Index Terms
    comfort ruling
  • Language
    English
  • Tax Analysts Electronic Citation
    90 TNT 157-17
Citations: Rev. Proc. 90-42; 1990-2 C.B. 420

Rev. Proc. 90-42

SECTION 1. BACKGROUND AND PURPOSE

01 Rev. Proc. 90-1, 1990-1 I.R.B. 8, provides procedures for issuing ruling letters involving substantive areas under the jurisdiction of the Associate Chief Counsel (Technical).

02 Announcement 90-65, 1990-20 I.R.B. 23, states that the "comfort ruling" policy set forth in section 3.01 and section 18.02 of Rev. Proc. 90-1 (the effective date of which was extended by Rev. Proc. 90-13, 1990-9 I.R.B. 23), will not go into effect and will be replaced with a variety of measures. These measures include specific no-rule areas, model documents, published ruling checklists, and automatic action revenue procedures.

SEC. 2. PROCEDURE

The procedures set forth in sections 3.10 and 18.02 of Rev. Proc. 90-1 are eliminated.

SEC. 3. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 90-1 is modified by deleting sections 3.10 and 18.02; Rev. Proc. 90-13 is revoked.

SEC. 4. EFFECTIVE DATE

This revenue procedure is effective for all ruling requests received under the procedures of Rev. Proc. 90-1.

DOCUMENT ATTRIBUTES
  • Index Terms
    comfort ruling
  • Language
    English
  • Tax Analysts Electronic Citation
    90 TNT 157-17
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