The Internal Revenue Service (IRS) is updating its temporary procedure for processing requests for certain expedited letter rulings for reorganizations and section 355 distribution. In addition, there is a new temporary address for the delivery of taxpayer requests for rulings, requests for determination letters, Applications for Change in Accounting Method (form 3115) and similar requests that are permitted to be hand-delivered to the main IRS building. These changes are necessary because of the closure of the main IRS Headquarters Building due to flood damage and will remain in effect until further notice.
The IRS established a pilot program for processing requests for letter rulings for reorganizations and section 355 distributions on an expedited basis, provided certain requirements were met. For expedited treatment as described in Revenue Procedures 2005-68 and 2006-1, taxpayers should fax their requests to (703) 605-1764. The temporary number previously announced no longer serves this function.
Further, requesters no longer need to contact an IRS attorney before making expedited ruling requests. Taxpayers should instead follow the normal instructions in Revenue Procedures 2005-68 and 2006-1. Taxpayers may call the Office of the Associate Chief Counsel (Corporate) at (202) 622-7242 or (202) 622-4038, if they have questions regarding this procedure.
Until further notice, requests for rulings, requests for determination letters, Applications for Change in Accounting Method (form 3115) and similar requests and applications should be delivered to: Courier's Desk, Room 105, First Floor, Internal Revenue Service, Attn: CC:PA:LPD:DRU, Crystal Mall4 Building at 1901 S. Bell St. or 1941 Jeff Davis Highway in Arlington, VA. This address as of Monday, August 14, 2006 will supersede the temporary address previously announced.
Complaints, subpoenas or any other service of process, as well as public comments on published guidance such as proposed regulations, normally delivered to the main IRS Headquarters building, should also be temporarily delivered to this same address. Documents previously hand-delivered to the main IRS Headquarters Building will be processed in the ordinary course.
All requests that are not hand=delivered should continue to be sent to Internal Revenue Service, Attn: CC:PA:DRU, P.O. Box 7604, Ben Franklin Station, Washington, D.C. 20044.