SECTION 16. WHAT IS THE

EFFECT OF TECHNICAL ADVICE?

p. 69 .01 Taxpayer notified .02 National office may provide views

p. 76 .01 Applies only to the taxpayer for whom technical advice was requested .02 Usually applies retroactively .03 Generally applied retroactively to modify or revoke prior technical

p. 70 .01 If requested, offered to the taxpayer when adverse technical advice

proposed .02 Normally held within 21 days of contact with the taxpayer .03 21-day period will be extended if justified and approved .04 Denial of extension cannot be appealed .05 Entitled to one conference of right .06 Conference may not be taped .07 Conference may be delayed to address a request for relief under

§ 7805(b) .08 Service makes tentative recommendations .09 Additional conferences may be offered .10 Additional information submitted after the conference .11 May, under limited circumstances, schedule a conference to be held by

telephone

p. 72 .01 Taxpayer or the taxpayer’s representative may request status .02 District director or chief, appeals office, may request status

p. 72 .01 Delegates authority to branch chiefs .02 Determines whether request has been properly made .03 Contacts the district or appeals office to discuss issues .04 Determines whether any matters in the request should be referred to

another branch .05 Informs the district or appeals office if additional information is needed .06 Gives tentative conclusion .07 If a tentative conclusion has not been reached, gives date estimated for

tentative conclusion .08 Advises the district or appeals office if tentative conclusion is changed .09 Discussion with the taxpayer regarding tentative conclusion .10 Advises the district or appeals office of final conclusions .11 If additional information is requested .12 Additional information sent to the national office and copy sent to the

district director or chief, appeals office .13 Informs the taxpayer when requested deletions will not be made .14 Prepares reply in two parts .15 Routes replies to appropriate office

p. 75 .01 Generally applies advice in processing the taxpayer’s case .02 Discussion with the taxpayer .03 Gives copy to the taxpayer .04 Taxpayer may protest deletions not made .05 When no copy is given to the taxpayer

advice .04 Applies to continuing action or series of actions until specifically

withdrawn, modified, or revoked .05 Applies to continuing action or series of actions until material facts

change

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