Rp 2023-26

HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.

ADMINISTRATIVE
Rev. Proc. 2023-26, page 486.

This revenue procedure describes a program that provides
an opportunity for fast-track processing of certain requests
for letter rulings solely or primarily under the jurisdiction of
the Associate Chief Counsel (Corporate). This new program
replaces the pilot program established by Rev. Proc. 202210, 2022-6 I.R.B. 473.

Finding Lists begin on page ii.




Bulletin No. 2023–33
August 14, 2023

Part III
26 CFR 601.201: Rulings and determination letters.

Rev. Proc. 2023-26
SECTION 1. PURPOSE
This revenue procedure describes a
program that provides an opportunity for
fast-track processing of certain requests
for letter rulings solely or primarily under
the jurisdiction of the Associate Chief
Counsel (Corporate). This new program
replaces the pilot program established by
Rev. Proc. 2022-10, 2022-6 I.R.B. 473.
SECTION 2. NOTABLE CHANGES
TO REV. PROC. 2022-10
The new program reflects two notable
changes to the program set forth in Rev.
Proc. 2022-10:
.01 Sections 4.02(2) and 5.08(2) of this
revenue procedure provide that fast-track
processing will not be granted if the letter
ruling includes a closing agreement with
respect to an issue under the jurisdiction of
the Associate Chief Counsel (Corporate) or
another Associate office. If the inclusion of
a closing agreement arises during the fasttrack processing of a letter ruling request,
the fast-track processing will be terminated, and the Internal Revenue Service
(IRS) will continue to process the letter ruling request under the procedures of section
7 of Rev. Proc. 2023-1. Expedited handling
under section 7.02(4) of Rev. Proc. 2023-1
remains available for such requests.
.02 Section 5.03(3) of this revenue
procedure clarifies that while a statement
providing one or more of the taxpayer’s
reasons for requesting fast-track processing is required, the taxpayer is not
required to demonstrate a business need
unless the taxpayer is requesting a ruling
in less than 12 weeks. The stated reason(s)
will be used as one factor to be considered
in making the determination of whether
a request for fast-track processing is
granted, and, if so, the length of the specified period defined in section 4.03 of this
revenue procedure.
SECTION 3. BACKGROUND
.01 Letter Rulings.

August 14, 2023

(1) In general. The IRS publishes
annually a revenue procedure to explain
how the IRS provides advice to taxpayers
on issues under the jurisdiction of each
Associate office. For example, Rev. Proc.
2023-1, 2023-1 I.R.B. 1, explains the
forms of advice and the manner in which
advice is requested by taxpayers and
provided by the IRS. References in this
revenue procedure to Rev. Proc. 2023-1
include references to successor revenue
procedures as appropriate.
(2) General instructions for requesting letter rulings. Section 7 of Rev. Proc.
2023‑1 provides general instructions and
procedures for requesting letter rulings
and determination letters.
(a) Expedited handling of letter ruling
requests. The IRS ordinarily processes
requests for letter rulings and determination letters in order of the date received.
However, section 7.02(4) of Rev. Proc.
2023-1 sets forth the procedures for
requesting expedited handling of letter
ruling requests (expedited handling). That
section requires a request for expedited
handling to be made in writing, preferably in a separate letter included with the
request for the letter ruling or provided
soon after its filing, and to explain in detail
the need for expedited handling. That section also sets forth the circumstances in
which the IRS will grant expedited handling of a letter ruling request. Specifically,
that section provides that a request for
expedited handling is granted only in rare
and unusual cases, out of fairness to other
taxpayers and because the IRS seeks to
process all requests as expeditiously as
possible and to give appropriate deference
to normal business exigencies in all cases.
Nevertheless, the IRS may grant a request
for expedited handling when a factor outside a taxpayer’s control creates a real
business need to obtain a letter ruling or
determination letter before a certain date
to avoid serious business consequences.
(b) Processing of letter ruling requests.
Section 8 of Rev. Proc. 2023-1 describes
the processing of letter ruling requests by
the Associate offices. Section 8.05(1) of
Rev. Proc. 2023-1 provides that, if a letter ruling request lacks essential information, the branch representative will request
such information, and that, unless an

486

extension of time is granted, the request
will be closed if the Associate office does
not receive the requested information
within 21 calendar days from the date
of the request. Section 8.05(2) of Rev.
Proc. 2023-1 provides that the IRS will
grant an extension of the 21-day period
if the extension is justified in writing by
the taxpayer and approved by the branch
reviewer. Section 8.05(3) of Rev. Proc.
2023-1 provides procedures for closing a
request if the taxpayer does not submit the
information requested within the specified
time.
(3) Conferences for letter rulings.
Section 10 of Rev. Proc. 2023-1 provides
procedures and rules regarding conferences between the taxpayer or the taxpayer’s authorized representative (taxpayer)
and IRS representatives to discuss a letter ruling request. A taxpayer generally is
entitled, as a matter of right, to only one
conference (conference of right). See Rev.
Proc. 2023-1, section 10.02.
.02 Pilot Program. In response to comments requesting faster processing of letter rulings, the Department of the Treasury
(Treasury Department) and the IRS issued
Rev. Proc. 2022-10 on January 14, 2022,
announcing an 18-month pilot program
to provide an opportunity for fast-track
processing of certain requests for letter
rulings solely or primarily under the jurisdiction of the Associate Chief Counsel
(Corporate). The Treasury Department
and the IRS have received favorable informal comments from practitioners regarding the pilot program. After considering
those comments and the results of the pilot
program, the Treasury Department and the
IRS have determined that it is in the best
interests of sound tax administration to
adopt the program set forth in this revenue
procedure.
SECTION 4. SCOPE
.01
Availability
of
Fast-Track
Processing. Except as provided in section
4.02 of this revenue procedure, a taxpayer
requesting a letter ruling solely or primarily under the jurisdiction of the Associate
Chief Counsel (Corporate) may request
fast-track processing but may not request
expedited handling of such request under

Bulletin No. 2023–33

section 7.02(4) of Rev. Proc. 2023-1. A
request for fast-track processing generally
will be granted if the letter ruling request
is solely under the jurisdiction of the
Associate Chief Counsel (Corporate), and
the requirements described in section 5 of
this revenue procedure are met. However,
if the letter ruling request is primarily
under the jurisdiction of the Associate
Chief Counsel (Corporate) but also
includes a request for a ruling on an issue
under the jurisdiction of another Associate
office, fast-track processing will be
granted only if the other Associate office
with jurisdiction over the issue agrees to
process the request in accordance with
this revenue procedure. If the letter ruling request is primarily under the jurisdiction of the Associate Chief Counsel
(Corporate) but also involves an issue
under the jurisdiction of another Associate
office, but no ruling with respect to such
issue is requested, fast-track processing
will be granted only if no other Associate
office with jurisdiction over the issue
objects to the request being processed in
accordance with this revenue procedure.
.02 Expedited Handling Available but
Not Fast-Track Processing. Expedited
handling under section 7.02(4) of Rev.
Proc. 2023-1, but not fast-track processing under this revenue procedure, may
be available for a letter ruling request
described in the following circumstances:
(1) A § 301.9100 request within the
meaning of section 5.03 of Rev. Proc.
2023-1 for extension of time for making an
election or for other applications for relief
under §§ 301.9100-1 through 301.9100-3
of the Procedure and Administration
Regulations (26 CFR part 301).
(2) Letter rulings that include a closing
agreement with respect to an issue under
the jurisdiction of the Associate Chief
Counsel (Corporate) or another Associate
office.
.03 Effect of Fast-Track Processing.
If a request for fast-track processing is
granted, the IRS will endeavor to complete processing of the letter ruling request
and, if appropriate, to issue the letter ruling within the time period specified by the
branch representative or branch reviewer
(specified period). The specified period
will be 12 weeks unless a shorter or longer period is designated by the branch
reviewer pursuant to section 5.06 of this

Bulletin No. 2023–33

revenue procedure. The specified period
begins on the following dates:
(1) If the letter ruling request involves
issues solely under the jurisdiction of the
Associate Chief Counsel (Corporate), the
specified period will begin on the date
the letter ruling request is assigned to and
received by the branch representative and
branch reviewer processing the letter ruling request.
(2) If the letter ruling request also
involves issues under the jurisdiction
of an Associate office other than the
Associate Chief Counsel (Corporate), the
specified period will begin on the first date
on which all other Associate offices having jurisdiction have informed the branch
representative or branch reviewer of their
agreement to fast-track processing (or, if
applicable, have indicated non-objection
to such processing).
SECTION 5. PROCEDURES FOR
FAST-TRACK PROCESSING
.01 Qualification. The IRS will provide fast-track processing of a letter ruling
request only if—
(1) the taxpayer satisfies each of the
requirements described in sections 5.02
through 5.04 of this revenue procedure
and agrees to satisfy the requirement
described in section 5.07 of this revenue
procedure; and
(2) after considering the factors listed
in section 5.05(2) of this revenue procedure, the branch reviewer determines that
fast-track processing is feasible.
.02 Pre-submission Conference.
(1) Request by taxpayer. The taxpayer
must request a pre-submission conference
with respect to the letter ruling request, in
accordance with the procedures described
in sections 10.07, 10.08, and 10.09 (as
added by section 6.02(3) of this revenue
procedure) of Rev. Proc. 2023‑1. In the
pre-submission conference, the taxpayer
should address both the substantive issues
and the taxpayer’s request for fast-track
processing.
(2) Required information before
pre-submission conference. Before the
pre-submission conference, the taxpayer
must provide the information required
pursuant to section 10.07(3) of Rev. Proc.
2023-1. Such information should include
a clear and concise description of the

487

transaction and issues to be discussed
during the pre-submission conference.
Additionally, the taxpayer must provide
a statement setting forth the reason(s)
for requesting fast-track processing, the
length of the specified period the taxpayer
requests (if other than 12 weeks), any
matters that could affect the feasibility
of fast-track processing, and any issues
under the jurisdiction of an Associate
office other than the Associate Chief
Counsel (Corporate) relevant to the transaction(s) (including whether a ruling will
be requested as to each such issue).
.03 Letter Ruling Request. A letter ruling request as to which fast-track processing is requested must satisfy all applicable
requirements of Rev. Proc. 2023-1 and
any other applicable revenue procedures
and, in addition, must include the items in
sections 5.03(1) through (5) of this revenue procedure.
(1) Required statement. The letter
ruling request must state, at the top of
the first page: “Fast-Track Processing
Is Requested under Revenue Procedure
2023‑26.”
(2) Required information. The letter
ruling request must include information
on the taxpayer’s reason(s) for requesting fast-track processing, the length of
the specified period the taxpayer requests
(if other than 12 weeks), any information
required by section 5.06 of this revenue
procedure if the specified period is less
than 12 weeks, any matters that could
affect the feasibility of fast-track processing, and any issues under the jurisdiction of an Associate office other than the
Associate Chief Counsel (Corporate) relevant to the transaction(s) (including any
rulings requested on any such issues).
(3) Rationale for fast-track processing.
The taxpayer must submit a statement providing one or more of the taxpayer’s reasons for requesting fast-track processing.
However, unless the taxpayer is requesting a specified period less than 12 weeks,
there is no requirement that the taxpayer
demonstrate a business need for requesting fast-track processing.
(4) Agreement regarding additional
information. The letter ruling request
must state that the taxpayer agrees to provide any additional information requested
by the branch representative or branch
reviewer within the seven business days

August 14, 2023

that begin on the next business day after
the day the request for information is
made (seven-day period). See section 5.07
of this revenue procedure.
(5) Draft letter ruling. The letter ruling
request must include a draft letter ruling
in a form that includes a legend of defined
terms, a description of relevant facts,
representations, requested rulings, and
administrative matters.
.04 Submitting Request for Letter
Ruling.
(1) Suggested submission by encrypted
email attachment. To avoid delay in processing of letter ruling requests submitted
by mail or delivered in physical form, it is
strongly recommended that a letter ruling
request for which fast-track processing
is requested be submitted by encrypted
email attachment, in accordance with section 7.04(3) of Rev. Proc. 2023-1.
(2) Submission other than by encrypted
email attachment. If a letter ruling
request for which fast-track processing
is requested is submitted other than by
encrypted email attachment, the draft letter ruling required by section 5.03(5) of
this revenue procedure must be submitted
separately by encrypted email attachment
in accordance with section 7.04(3) of Rev.
Proc. 2023-1.
.05 Notification of Receipt and Granting
of Request for Fast-Track Processing.
(1) Notification. No later than seven
business days after the day the letter ruling
request is assigned to and received by the
branch representative and branch reviewer,
the branch representative or branch reviewer
will contact the taxpayer to acknowledge
receipt of the letter ruling request, to provide contact information for the branch
representative and branch reviewer, and
to notify the taxpayer that the request for
fast-track processing is granted, denied, or
still pending. If the request is granted, the
branch representative or branch reviewer
will inform the taxpayer of the length of the
specified period and the date the specified
period will end. If the request is denied, the
branch representative or branch reviewer
will explain the reasons for the denial. If the
request is under consideration by another
Associate office at that time, the branch
representative or branch reviewer will so
inform the taxpayer.
(2) Factors in determining whether
a request for fast-track processing will

August 14, 2023

be granted. In making the determination
whether to grant a request for fast-track
processing, and, if so, the length of the
specified period, the branch reviewer will
consider—
(a) All the facts, representations, and
circumstances, including the complexity of the proposed transactions, and the
issues presented;
(b) Whether the letter ruling request
fully, clearly, and concisely describes and
analyzes the relevant facts and issues;
(c) Whether the draft letter ruling satisfies the requirements set forth in section
5.03 of this revenue procedure;
(d) The taxpayer’s reason(s) for
requesting fast-track processing as set
forth in a statement provided under section 5.03(3) of this revenue procedure;
(e) Any concerns communicated by
another Associate office; and
(f) Any resource constraints or other
obligations of the Associate Chief Counsel
(Corporate), including responsibilities
with respect to examination matters, litigation matters, guidance projects, assistances provided to other Associate offices,
and other letter ruling requests.
(3) Opportunity for discussion and
reconsideration; tolling. If the branch representative or the branch reviewer informs
the taxpayer that the request for fast-track
processing is denied, the taxpayer may
address that determination in writing, discuss that determination with the branch
reviewer, or both. If the branch reviewer
continues to determine that the request for
fast-track processing should be denied,
there is no right of appeal. See section 10.02
of Rev. Proc. 2023-1. If, after reconsideration, the branch reviewer determines that
the request for fast-track processing should
be granted, the specified period will be
tolled for the period beginning on the date
the taxpayer was informed that the request
for fast-track-processing was denied and
ending on the date the taxpayer is informed
of the determination that such request is
granted. The branch representative or the
branch reviewer will inform the taxpayer
that a favorable or unfavorable determination has been made as soon as possible
after the determination has been made and,
in the event of a favorable determination,
the period of tolling of the specified period.
.06 Specified Period Shorter or Longer
than 12 Weeks.

488

(1) Request for specified period shorter
than 12 weeks.
(a) In general. Upon request, the IRS
will agree to a specified period shorter than
12 weeks if the branch reviewer determines
that the taxpayer has a business need to
obtain a letter ruling within that specified
period, and that processing is feasible.
(b) Business need. In a request for a
specified period shorter than 12 weeks,
the taxpayer must demonstrate a need for
such processing by submitting information to support the following conclusions,
no later than the date on which the letter
ruling request is submitted:
(i) There is a business exigency outside
the taxpayer’s control.
(ii) There will be adverse consequences
to the taxpayer or other persons if the IRS
does not issue the requested letter ruling
within the specified period.
(iii) The taxpayer submitted the request
as promptly as possible after becoming
aware of the circumstances described
in paragraphs (i) and (ii) of this section
5.06(1)(b).
(c) Insufficient reasons. The following
facts alone do not demonstrate a need for
a specified period shorter than 12 weeks:
(i) The scheduling of a closing date
for a transaction, a meeting of a board of
directors or shareholders of a corporation,
or any other corporate action within the
control of the taxpayer or other parties to
the transaction.
(ii) The possible effect of fluctuation in
the market price of stocks on a transaction.
(2) Specified period longer than 12
weeks.
(a) Taxpayer request. Upon request by
the taxpayer, the branch reviewer may
agree to a specified period longer than 12
weeks.
(b) Branch reviewer determination.
The branch reviewer may decide to designate a specified period longer than 12
weeks, if he or she determines (based on
the factors described in section 5.05(2)
of this revenue procedure) that fast-track
processing is not feasible within 12 weeks
(or other specified period requested by
the taxpayer) but is feasible during the
longer period. In such a case, the branch
representative or branch reviewer will
inform the taxpayer of the decision and
the reasons therefor and will provide the
taxpayer an opportunity to address the

Bulletin No. 2023–33

decision. The branch representative or the
branch reviewer will inform the taxpayer
of any subsequent favorable or unfavorable determination.
(3) Same procedures apply. The procedures described in this revenue procedure
apply to all requests for fast-track processing, regardless of whether the specified
period is 12 weeks or is shorter or longer
than 12 weeks.
.07 Requested Additional Information
Not Received Within Seven-Day Period.
If the branch representative or branch
reviewer requests additional information,
but all the requested information is not
received within the seven-day period, then,
unless the taxpayer requests an extension
before the end of the seven-day period,
and the branch reviewer grants the extension, fast-track processing will be terminated. A request for an extension of the
seven-day period may be made orally, in
writing, or both. However, the seven-day
period will not be tolled after an extension
is requested unless agreed to by the branch
reviewer. The branch reviewer will grant
an extension only if the taxpayer provides
good cause therefor. If an extension of
time to submit information is granted, and
the requested information is not provided
within the extended time, fast-track processing will also be terminated unless a
further extension is requested and granted.
If fast-track processing is terminated
under this section, the request will be subject to the procedures described in section
5.08 of this revenue procedure.
.08 Termination or Delay of Fast-Track
Processing.
(1) In general. If the branch reviewer
determines that fast-track processing
within the specified period is no longer
feasible, the branch reviewer may terminate fast-track processing or determine
that fast-track processing will be completed within a newly designated specified
period.
(2) Rationale for determination. In
determining whether fast-track processing
is no longer feasible within the specified
period, the branch reviewer will consider
any event or situation that affects the IRS’s
ability to provide fast-track processing
within the specified period, including—
(a) Any material change to the proposed transaction(s) since submission of
the letter ruling request;

Bulletin No. 2023–33

(b) Any Federal income tax issue not
addressed in the original letter ruling
request and subsequently identified;
(c) The accuracy or completeness of
any additional information submitted;
(d) Any pending legislation, regulations, or other guidance that may affect
the proposed transaction(s);
(e) Any resource constraints or other
obligations of the Associate Chief Counsel
(Corporate), including responsibilities
with respect to examination matters, litigation matters, guidance projects, assistances provided to other Associate offices,
and other letter ruling requests;
(f) The subsequent inclusion of a closing agreement in the letter ruling request;
and
(g) The scheduling of a conference of
right described in section 10.02 of Rev.
Proc. 2023-1 or a similar conference.
(3) Notification and opportunity for
discussion and reconsideration; tolling.
If the branch representative or the branch
reviewer informs the taxpayer that fasttrack processing has been terminated, the
specified period has been extended, or the
completion of fast-track processing has
otherwise been delayed, the taxpayer may
address that determination in writing, discuss that determination with the branch
reviewer, or both. If, upon reconsideration,
the branch reviewer continues to determine that the request for fast-track processing should be terminated, the specified
period should be extended, or completion
of fast-track processing will otherwise be
delayed, there is no right of appeal. See
section 10.02 of Rev. Proc. 2023-1. If,
upon reconsideration, the branch reviewer
determines that fast-track processing
should not be terminated, the specified
period should not be extended, or completion of fast-track processing should not
be otherwise delayed, the specified period
will be tolled for the period beginning on
the date the taxpayer was informed of the
initial unfavorable determination and ending on the date the taxpayer is informed of
the subsequent favorable determination.
The branch representative or the branch
reviewer will inform the taxpayer that a
determination following reconsideration
has been made as soon as possible after
the determination has been made and, in
the event of a favorable determination, the
period of tolling of the specified period.

489

(4) Continued processing of letter ruling request. If fast-track processing is terminated, the IRS will continue to process
the letter ruling request under the procedures of section 7 (exclusive of section
7.02(4)) of Rev. Proc. 2023-1. However,
if fast track processing is terminated
because a closing agreement that was not
initially part of a letter ruling request is
subsequently included with a letter ruling
request, the IRS will continue to process
the letter ruling request under the procedures of section 7 of Rev. Proc. 2023-1,
and will consider a request for expedited
handling under section 7.02(4) of that revenue procedure.
SECTION 6. MODIFICATIONS TO
REV. PROC. 2023-1
Rev. Proc. 2023-1 is modified as
follows:
.01 Requests for Expedited Handling.
Section 7.02(4) of Rev. Proc. 2023-1 is
modified by adding the following language at the end of the first paragraph:
“Expedited handling under this section
7.02(4) is not available as to a request
for a letter ruling solely or primarily
under the jurisdiction of the Associate
Chief Counsel (Corporate) (other than
a § 301.9100 request described in section 5.03 of this revenue procedure
for an extension of time for making
an election or other relief, or a request
that includes a closing agreement with
respect to an issue under the jurisdiction of the Associate Chief Counsel
(Corporate) or another Associate
office). For guidance on fast-track processing of such a letter ruling request,
see Rev. Proc. 2023-26, 2023-33 I.R.B.
486.”
.02 Additional Information. Section
8.05(1) of Rev. Proc. 2023-1 is modified
by adding the following language at the
end of the first paragraph:
“Special rules and procedures apply to
letter ruling requests under the jurisdiction of the Associate Chief Counsel
(Corporate) for which fast-track processing is requested. Under section
5.07 of Rev. Proc. 2023-26, failure to
provide, within seven business days
(plus extensions, if granted), a complete response to any information
request from the branch representative

August 14, 2023

or branch reviewer assigned to the letter ruling request will result in termination of fast-track processing.”

.03 Conferences for Letter Rulings.
Section 10 of Rev. Proc. 2023-1 is

Pre-submission conferences
under Rev. Proc. 2023-26.

.04 List of Guideline Revenue
Procedures. Section .01 of Appendix
F of Rev. Proc. 2023-1 is modified by

.09 Special rules and procedures apply to letter ruling requests
solely or primarily under the jurisdiction of the Associate Chief
Counsel (Corporate) for which fast-track processing has been
requested. For more information, see section 5.02 of Rev. Proc.
2023-26.
adding the following entry to the subject
matter list of guideline revenue procedures immediately before “Intercompany

Fast-track processing of letter ruling requests solely or primarily under the jurisdiction of the Associate Chief Counsel
(Corporate).
SECTION 7. EFFECT ON OTHER
DOCUMENTS
.01 Rev. Proc. 2022-10. Rev. Proc.
2022-10 is superseded for letter ruling
requests described in section 8 of this revenue procedure.
.02 Rev. Proc. 2023-1. Rev. Proc.
2023-1 is modified as provided in section
6 of this revenue procedure.
SECTION 8. APPLICABILITY DATE
The fast-track ruling program established by this revenue procedure applies
to all letter ruling requests described in
section 4.01 of this revenue procedure
postmarked or, if not mailed, received by
the IRS after July 26, 2023.
SECTION 9. PAPERWORK
REDUCTION ACT
The collections of information in
this revenue procedure have been
reviewed and approved by the Office
of Management and Budget (OMB)
in accordance with the Paperwork
Reduction Act (44 U.S.C. 3507) under
control number 1545-1522.

August 14, 2023

modified by adding the following new
paragraph at the end:

transactions; election not to defer gain or
loss”:

Rev. Proc. 2023-26, 2023-33 I.R.B. 486.

An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
The collections of information in this
revenue procedure are in section 5. This
information is required to determine
whether a taxpayer qualifies for fast-track
processing. The collections of information
are required to obtain a benefit. The likely
respondents are corporations seeking private letter rulings.
The estimated total annual reporting
and/or recordkeeping burden for Rev.
Proc. 2023-1 is 316,020 hours.
The estimated annual burden per
respondent/recordkeeper for Rev. Proc.
2023-1 varies from 1 to 200 hours,
depending on individual circumstances,
with an estimated average burden of 80
hours. The estimated number of respondents and/or recordkeepers is 3,956.
The estimated total annual reporting
and/or recordkeeping burden for this revenue procedure adds 260 hours to the burden imposed by Rev. Proc. 2023-1.
The estimated annual burden per
respondent/recordkeeper for this revenue

490

procedure varies from 3 to 10 hours,
depending on individual circumstances,
with an estimate average burden of 8
hours. The estimated number of additional respondents and/or recordkeepers added to Rev. Proc. 2023-1 by this
revenue procedure is 10, increasing the
estimated number of respondents and/
or recordkeepers to Rev. Proc. 2023-1 to
3,966.
The estimated annual frequency of
response is on occasion.
Books or records relating to a collection of information must be retained as
long as their contents may become material in the administration of any internal
revenue tax law. Generally, tax returns and
tax return information are confidential, as
required by section 6103 of the Internal
Revenue Code.
SECTION 10. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Kelton P. Frye of the Office
of Associate Chief Counsel (Corporate).
For further information, please call Mr.
Frye at (202) 317-5363.

Bulletin No. 2023–33