604.18—Request for an advisory opinion.
(a)
An interested party may request an advisory opinion from the Chief Counsel on a matter regarding specific factual events only.
(b)
A request for an advisory opinion shall be submitted in the following form:
(c)
The Chief Counsel may request additional information, as necessary, from the party submitting the request for an advisory opinion.
(d)
A request for an advisory opinion may be denied if:
(1)
The request contains incomplete information on which to base an informed advisory opinion;
(2)
The Chief Counsel concludes that an advisory opinion cannot reasonably be given on the matter involved;
(3)
The matter is adequately covered by a prior advisory opinion or a regulation;
(4)
The Chief Counsel otherwise concludes that an advisory opinion would not be in the public interest.