Introduction›Rev. Proc. 96-3, page 82.
SECTION 10. HOW DOES A
Internal Revenue Bulletin 1996-1 · 2026-10-03 edition · updated 2026-10-04 · United States
TAXPAYER APPEAL A DISTRICT DIRECTOR OR CHIEF, APPEALS OFFICE, DECISION NOT TO SEEK TECHNICAL ADVICE?
Taxpayer notified of decision not to seek technical advice
Taxpayer may appeal decision not to seek technical advice
.01 If the examining officer or appeals officer concludes that a taxpayer’s request for referral of an issue to the national office for technical advice does not warrant referral, the examining officer or appeals officer will tell the taxpayer. A taxpayer’s request for such a referral will not be denied merely because the national office provided legal advice, other than advice furnished pursuant to this revenue procedure, to the district or appeals office on the matter.
.02 The taxpayer may appeal the decision of the examining officer or appeals officer not to request technical advice. To do so, the taxpayer must submit to that official, within 10 calendar days after being told of the decision, a statement of the facts, law, and arguments on the issue and the reasons why the taxpayer believes the matter should be referred to the national office for technical advice. A taxpayer who needs more than 10 calendar days must justify in writing the request for an extension of time. The extension is subject to the approval of the chief, examination division, or the chief, appeals office.
Sec. 68
Chief, examination division, or chief, appeals office, determines whether technical advice will be sought
Chief’s decision may be reviewed but not appealed
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