SECTION 1. PURPOSE

.01 This revenue procedure provides the rules applicable to a new pilot program under which pre-submission conferences may be held in the national office for matters that a district director or a chief, appeals office, is preparing to submit for technical advice under Rev. Proc. 97–2, 1997–1 I.R.B. 64.

.02 In an effort to promote expeditious processing of requests for technical advice, national office personnel generally will meet with the district or appeals office personnel and the taxpayer prior to the time a request for technical advice is submitted to the national office. The pre-submission conference procedures set forth in this revenue procedure are intended to facilitate agreement between the parties as to the appropriate scope of the request for technical advice, the factual information to be included in the request for technical advice, any collateral issues that either should or should not be included in the request for technical advice, and any other substantive or procedural considerations that will allow the national office to provide the parties with technical advice as expeditiously as possible.

.03 The pre-submission conference procedures are not intended to create alternative procedures for determining the merits of the substantive positions advocated by the district or appeals office or by the taxpayer, but instead are intended only to facilitate the overall technical advice process.