This revenue procedure amplifies Rev. Proc. 2007-3, 2007-1 I.R.B. 108, which sets forth areas of the Internal Revenue Code in which the Internal Revenue Service will not issue letter rulings or determination letters.
Section 3 of Rev. Proc. 2007-3 sets forth a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) relating to issues on which the Internal Revenue Service will not issue letter rulings or determination letters.
Rev. Proc. 2007-3 is amplified by adding the following to section 3.01: Section 102. Gifts and Inheritances. Whether a transfer is a gift within the meaning of ยง 102(a).
This revenue procedure applies to all ruling requests pending or received in the National Office on or after June 1, 2007.
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