SECTION 10. HOW DOES A

TAXPAYER APPEAL A DISTRICT DIRECTOR OR CHIEF, APPEALS OFFICE, DECISION NOT TO SEEK TECHNICAL ADVICE?

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p. 62

p. 63 .01 Issues under the jurisdiction of the Associate Chief Counsel (Domestic),

the Associate Chief Counsel (Employee Benefits and Exempt Organizations), the Associate Chief Counsel (Enforcement Litigation), or the Associate Chief Counsel (International)

.02 Issues involving shipowners’ protection and indemnity associations and

certain homeowners associations

p. 63 .01 Alcohol, tobacco, and firearms taxes

.02 Employee plans and exempt organizations

.03 Farmers’ cooperatives

p. 64 .01 Section 301.9100–1 request is a letter ruling request

.02 Statute of limitations

.03 Address to send a § 301.9100–1 request

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

the national office will notify the district or appeals office

p. 64 .01 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. 65 .01 Uniformity of position lacking

.02 When technical advice can be requested

.03 At the earliest possible stage

p. 65 .01 Statement of issues, facts, law, and arguments

.02 Statement identifying information to be deleted from public inspection

.03 Transmittal Form 4463, Request for Technical Advice

.04 Number of copies of request to be submitted

.05 Power of attorney

p. 67 .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

.05 If the taxpayer has not submitted the required deletions statement

.06 Section 6104 of the Internal Revenue Code (Applications for exemption

and letter rulings issued to certain exempt organizations open to public inspection)

.07 Criminal or civil fraud cases

p. 68 .01 Taxpayer notified of decision not to seek technical advice

.02 Taxpayer may appeal decision not to seek technical advice

.03 Chief, examination division, or chief, appeals office, determines whether

technical advice will be sought .04 Chief’s decision may be reviewed but not appealed

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