SECTION 14. HOW DOES THE

NATIONAL OFFICE PREPARE THE TECHNICAL ADVICE MEMORANDUM?

p. 73 .01 Taxpayer notified of decision not to seek technical advice

.02 Taxpayer may appeal decision not to seek technical advice

.03 Chief, examination division, or chief, appeals office, determines whether technical advice will be sought

.04 Chief’s decision may be reviewed but not appealed

p. 73 .01 Taxpayer notified

.02 National office may provide views

p. 74 .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 If requested and approved, conference will 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 Under limited circumstances, may schedule a conference to be held by telephone

p. 76 .01 Taxpayer or the taxpayer’s representative may request status from the district or appeals office

.02 District director or chief, appeals office, may request status from the national office

p. 76 .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 Informs the district or appeals office if any matters in the request have been referred to another branch or office

.05 Informs the district or appeals office if additional information is needed

.06 Informs the district or appeals office of the 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 Generally does not discuss the tentative conclusion with the taxpayer

.10 Advises the district or appeals office of final conclusions

.11 If needed, requests additional information

.12 Requests taxpayer to send additional information to the national office and a copy 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

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