SERVICE EXTENDS EFFECTIVE DATE FOR IMPLEMENTATION OF COMFORT RULING POLICY.

Rev. Proc. 90-13

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). Section 3.10 of Rev. Proc. 90-1 requires that ruling requests submitted on or after February 5, 1990, must contain a statement explaining why the requested ruling is not adequately addressed by published authority. Section 18.02 of the Rev. Proc. 90-1 provides that for ruling requests submitted on or after February 5, 1990, the Internal Revenue Service will not rule, except in extraordinary circumstances, on issues that are clearly and adequately addressed by published authority.

02 In Announcement 89-104, 1989-35 I.R.B. 19, and Announcement 89-105, 1989-35 I.R.B. 20, the Service invited public comment regarding possible modifications to the "comfort ruling" policy under which the Office of Associate Chief Counsel (Technical) will discontinue, except in extraordinary circumstances, the issuance of letter rulings with respect to issues that are clearly and adequately addressed by published authority.

03 Announcement 90-21, 1990-6 I.R.B. 28, states that in order for the Office of Associate Chief Counsel (Technical) to have sufficient time to evaluate comments received concerning Announcements 89-104 and 89-105, the February 5, 1990, effective date for implementation of the "comfort ruling" policy set forth in section 3.01 and section 18.02 of Rev. Proc. 90-1, will be extended.

SEC. 2. PROCEDURE

Sections 3.10 and 18.02 of Rev. Proc. 90-1 are modified by deleting "February 5, 1990" and inserting in place thereof "May 7, 1990" in each section.

SEC. 3. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 90-1 is modified.

SEC. 4. EFFECTIVE DATE

This revenue procedure applies to all ruling requests postmarked or, if not mailed, received on or after February 5, 1990.