The Internal Revenue Service has agreed to withdraw a ruling that would have eliminated a tax deduction for donations that were made to college scholarship programs in return for the right to buy preferred-seating tickets to football games.

The IRS has said it will hold off in applying the ruling until the public has had a chance to comment on it. Sen. John Heinz (R-Pa.) was prepared to amend the debt ceiling bill to strike down the IRS ruling, but withdrew his proposed amendment after the IRS action was announced. "This is a very serious problem where the IRS overreacted," said Heinz.

The IRS had ruled that contributions to athletic scholarship programs were not tax deductible if the donor got something of value in return. The IRS used as an example a taxpayer who gave $300 a year to an athletic scholarship program. For that amount his name was placed on a waiting list for tickets to the school's home football games. If he donated $120 more, he could qualify for tickets between the 40-yard lines. A taxpayer would have to prove that the right to buy preferred seating was worth less than the amount donated to qualify for a tax deduction, the IRS had said.

After it receives the comments, the IRS could still make the same decision. WHO ASKED YOU? . . .

The IRS commissioner's advisory group will meet Nov. 1 and 2 with Commissioner Roscoe L. Egger Jr. and senior IRS staff members to discuss tax administration issues. The agenda includes automated collection methods, penalty provisions, prefiling programs and summon procedures. The group has 17 members -- accountants, attorneys, government officials, small-business executives and others, who are appointed by professional groups in the tax field. GIMME SHELTER . . .

"Tax shelters, formerly the bailiwick only of the wealthy sophisticated investor, are now creeping into the tax returns of middle- and even lower-income taxpayers," Egger said in a recent speech. "But the sad fact is that these taxpayers are buying into some of the most egregious, abusive schemes you can imagine."

Egger said that an IRS service center recently had analyzed 71 tax-shelter schemes that had been identified as questionable refund cases. Of that number, 25 involved middle- and lower-income taxpayers." . . . These people don't make hundreds of thousands . . . . They're our next-door neighbors who make $25,000," Egger said.

"Ordinarily, I'm not one for slogans, but in this case, I might make an exception: 'Shelter at your own risk.' "