SECTION 3. PROCEDURES FOR

REQUESTING EARLY REFERRAL

.01 Initiating the early referral re- quest. A request for early referral must be submitted in writing by the CEP taxpayer to the CEP case manager. The CEP case manager may suggest that a CEP taxpayer make such a request.

.02 Statement of issues and posi- tion. An early referral request must:

(1) state the issues for which early referral is requested;

(2) identify the taxpayer (and, where applicable, all related persons involved in the issue(s)) and the tax period(s) to which those issues relate; and

(3) describe the taxpayer’s and the Service’s position with regard to the relevant early referral issues. This

statement must contain a brief discussion of the material facts and an analysis of the facts and law as they apply to the early referral issues.

.03 Perjury Statement. The early referral request, and any supplemental submission (including additional documents), must include a declaration in the following form:

Under penalties of perjury, I declare that I have examined this request [or submission], includ- ing accompanying documents, and to the best of my knowledge and belief, the facts presented are true, correct, and complete.

This declaration must be signed by any person currently authorized to sign the taxpayer’s federal income tax returns.

.04 Signatures. A request for early referral must be signed by the taxpayer or the taxpayer’s authorized representative. It is preferred that Form 2848, Power of Attorney and Declaration of Representative, be used with regard to an early referral request under this revenue procedure.