SECTION 1. PURPOSE

Early referral is a process to resolve Coordinated Examination Program (CEP) cases more expeditiously through Examination and Appeals working simultaneously. This revenue procedure describes the method by which a taxpayer requests early referral of one or more unagreed issues from Examination to Appeals. This revenue procedure does not alter the District Director’s authority to audit the returns of a taxpayer nor limit or expand the District Director’s authority to resolve any issues, including the authority in Delegation Order No. 236, 1991–1 C.B. 313.