TN 3 (08-89)

Submit to the Chief Counsel of the appropriate region any case where State law is not clear or the individual is protesting a denial of an underpayment and

• there is no precedent as to whether an individual, designated to receive assets of the deceased under a State statute, can give “good acquittance” for the payment, or

• the value of the assets of the decedent's estate, including the underpayment, exceeds the amount set forth in the particular State's statute as the maximum amount for which the procedure is applicable.