Introduction›Rev. Proc. 96-3, page 82.
SECTION 11. HOW DOES A
Internal Revenue Bulletin 1996-1 · 2026-10-03 edition · updated 2026-10-04 · United States
TAXPAYER APPEAL A KEY DISTRICT OR AN APPEALS OFFICE DECISION NOT TO SEEK TECHNICAL ADVICE?
Taxpayer notified of decision not to seek technical advice
.01 If the EP/EO specialist 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 EP/EO specialist 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 key district or appeals office on the matter.
Sec. 138
Taxpayer may appeal decision not to seek technical advice
Chief, EP/EO division, or chief, appeals office, determines whether technical advice will be sought
Chief’s decision may be reviewed but not appealed
Get a plain-English answer with a citation back to this text.
Ask AI about this code