SECTION 1. WHAT IS THE

PURPOSE OF THIS REVENUE PROCEDURE?

Description of terms used in this revenue procedure

This revenue procedure explains when and how the Associate Chief Counsel (Domestic), the Associate Chief Counsel (Employee Benefits and Exempt Organizations), the Associate Chief Counsel (Enforcement Litigation), and the Associate Chief Counsel (International) give technical advice to a district director or a chief, appeals office. It also explains the rights a taxpayer has when a district director or a chief, appeals office, requests technical advice regarding a tax matter.

For purposes of this revenue procedure—

(1) any reference to district director or district office includes their respective offices or, when appropriate, the Assistant Commissioner (International) or the director of an Internal Revenue Service Center;

(2) any reference to chief, appeals office, includes, when appropriate, the assistant regional director of appeals (large case);

(3) any reference to chief, examination division includes, when appropriate, the chief, employee plans/exempt organizations division;

(4) any reference to appeals officer includes, when appropriate, the team chief;

(5) the word ‘‘taxpayer’’ includes all persons subject to any provision of the Internal Revenue Code (including issuers of § 103 obligations) and, when appropriate, their representatives; and

(6) the word ‘‘national office’’ refers to the Office of Associate Chief Counsel (Domestic), the Office of Associate Chief Counsel (Employee Benefits and Exempt Organizations), the Office of Associate Chief Counsel (Enforcement Litigation), or the Office of Associate Chief Counsel (International), as appropriate.

Updated annually The revenue procedure is updated annually as the second revenue procedure of the year, but may be modified or amplified during the year.