Taxpayers who entered into a binding
agreement on or after January 28, 1998 (the effective date of Sec.
1.368-1T), and before the effective date of the final regulations
under Sec. 1.368-1(e) may request a private letter ruling
permitting them to apply Sec. 1.368-1(e) to their transaction. A
private letter ruling will not be issued unless the taxpayer
establishes to the satisfaction of the IRS that there is not a
significant risk of different parties to the transaction taking
inconsistent positions, for U.S, tax purposes with respect to the
applicability of Sec. 1.368-1(e) to the transaction.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.