The IRS will usually not issue a substantive ruling. The Service is frequently unable to determine, based on the facts available, what the true Taxpayer's motivations are since interpreting the facts can very often be subjective. In general, a negative ruling is sent to the field office in the IRS District where the individual files his or her return. This may result in the return being audited. If a negative ruling is going to be issued, the taxpayer can request a conference with the IRS if he or she thinks that this will help to clarify the facts.
Taxpayers can withdraw their ruling.
While the Service will not necessarily initiate any follow-up action, the process is somewhat complicated by the withdrawal. The Taxpayer should avoid this action is possible. There are six international branches in Washington. Branch 1 handles tax treaties and expatriation. The examiners are typically attorneys with several years of experience.