The IRS ordinarily does not issue a determination letter if, at the time of the request, the identical issue is involved in the taxpayer’s return for an earlier period and that issue:
- is being examined by an IRS field office;
- is being considered by an IRS Appeals office;
- is pending in litigation in a case involving the taxpayer or a related party;
- has been examined by a field office or considered by Appeals and the statutory period of limitations on assessment or on filing a claim for refund or credit of tax has not expired; or
- has been examined by a field office or considered by Appeals and a closing agreement covering the issue or liability has not been entered into by a field office or by Appeals.
The IRS ordinarily does not issue determination letters in certain areas because of the factual nature of the matter involved or for other reasons.
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