SECTION 10. HOW ARE

REQUESTS HANDLED?

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p. 132 .01 Issues under the jurisdiction of the Assistant Commissioner (Employee

Plans and Exempt Organizations)

.02 Farmers’ cooperatives

.03 Basis for requesting technical advice

.04 Areas of mandatory technical advice

p. 133 .01 Matters (other than farmers’ cooperatives) under the jurisdiction of the

Associate Chief Counsel (Domestic), the Associate Chief Counsel (Employee Benefits and Exempt Organizations), and the Associate Chief Counsel (International)

.02 Alcohol, tobacco, and firearms taxes

.03 Excise taxes

p. 133 .01 Generally a § 301.9100–1 request is a letter ruling request.

.02 Statute of limitations

.03 Address to send a § 301.9001–1 request

.04 If return is being examined, taxpayer must notify the national office

which will notify the key district or appeals office

p. 134 .01 Key district director or chief, appeals office determines whether

technical advice should be requested

.02 Taxpayer may ask that issue be referred for technical advice

p. 134 .01 Uniformity of position lacking

.02 When technical advice can be requested

.03 At earliest possible stage

p. 135 .01 Statement of issues, facts, law, and arguments

.02 Statement pertaining to statute of limitations

.03 General provisions of §§ 6104 and 6110 of the Code

.04 Application of § 6104 of the Code

.05 Statement identifying information to be deleted from public inspection

.06 Transmittal Form 5565, Request for Technical Advice—EP/EO

.07 Number of copies of request to be submitted

.08 Power of attorney

.09 Case files

p. 137 .01 Taxpayer notified

.02 Conference offered

.03 If the taxpayer disagrees with the Service’s statement of facts

.04 If the Service disagrees with the taxpayer’s statement of facts

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