SECTION 6. THE DISTRICT
Internal Revenue Bulletin 1998-49 · 2026-10-03 edition · updated 2026-10-04 · United States
FORWARDS CASE FILE TO APPEALS
After the issuer has requested an appeal and has responded in writing to the notice of an adverse determination, the District will forward the agent’s file to Appeals. The file should include copies of the following:
the technical advice memorandum, if any;
all information received by the agent from the issuer regarding the Bond Issue;
all work papers of the agent examining the Bond Issue;
the District’s notice;
the issuer’s written appeal request;
the issuer’s written response to the notice; and
the District’s response to the issuer’s position, if any.
After the agent’s file is sent to Appeals, Appeals will have jurisdiction over the Bond Issue.
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