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Washington Tax Alert - January 6, 2009

Washington Tax Alert from Don Barnes, dbarnes@washingtontaxlaw.com

January 6, 2009

The Service has issued the annual revenue procedure for 2009 setting forth the terms and conditions for obtaining letter rulings and other advice from the National Office. See Rev. Proc. 2009-1. There are no significant changes from Rev. Proc. 2008-1.

The user fee for letter rulings is $11,500, and the user fee for non-automatic requests for change in accounting method (Form 3115) is $3,800. These amounts were last increased on February 1, 2008, and there is no indication the Service is considering a future increase in either amount.

A request for 9100 relief ( i.e. , a request for extension of time to make an election or other application for relief under Treas. Reg. § 301.9100-3) is treated as a request for a letter ruling and is subject to the $11,500 user fee. The IRS National Office will consider a 9100 application even after a tax return for the year in question has been filed, an examination of the return has begun, or the issue is under consideration by the Appeals Office.