SECTION 3. SCOPE

.01 In general. All issues raised by the District during an examination of a Bond Issue that would cause the interest on the Bond Issue not to be excludable from gross income under § 103 of the Code are appropriate for consideration by Appeals. The appeal is optional and is initiated by the issuer as described below.

.02 Issuers may request technical ad- vice referral. For purposes of examining Bond Issues, issuers are treated as taxpayers. Thus, the procedures for requesting technical advice referral that apply to all taxpayers apply to issuers of Bond Issues

under examination. See § 601.105 et seq. of the Statement of Procedural Rules and Rev. Proc. 98–2, 1998–1 I.R.B. 74, or subsequent procedure.

.03 Early referral. Section 3465 of the Act provides that the Service shall prescribe procedures by which a taxpayer may request early referral of one or more unresolved issues to Appeals. Prior to the adoption of generally applicable early referral procedures, an issuer may make a separate request to the District for the early referral to Appeals of one or more issues regarding a Bond Issue set forth in section 3.01.