SECTION 21. WHAT IS THE p. 107

EFFECTIVE DATE OF THIS REVENUE PROCEDURE?

DRAFTING INFORMATION p. 107

INDEX p. 109

SECTION 1. WHAT IS THE This revenue procedure explains when and how the Associate Chief Counsel (Corporate), PURPOSE OF THIS REVENUE the Associate Chief Counsel (Financial Institutions & Products), the Associate Chief PROCEDURE? Counsel (Income Tax & Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs & Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) give technical advice to a director or an area director, appeals. It also explains the rights a taxpayer has when a director or an area director, appeals, requests technical advice regarding a tax matter.

Operating divisions of the The Internal Revenue Service includes four operating divisions that are responsible for Internal Revenue Service meeting the needs of the taxpayers they serve. These operating divisions are:

(1) Large and Mid-Size Business Division (LMSB), which generally serves corporations, S corporations, and partnerships with assets in excess of $5 million;

(2) Small Business/Self-Employed Division (SB/SE), which generally serves corporations, S corporations, and partnerships with assets less than or equal to $5 million; estates and trusts; individuals filing an individual federal income tax return with accompanying Schedule C (Profit or Loss from Business (Sole Proprietorship)), Schedule E (Supplemental Income and Loss), or Schedule F (Profit or Loss from Farming), or Form 2106 (Employee Business Expenses) or Form 2106-EZ (Unreimbursed Employee Business Expenses); and individuals with international tax returns;

(3) Wage and Investment Division (W&I), which generally serves individuals with wage and investment income only and with no international tax returns, filing an individual federal income tax return without accompanying Schedule C, E, or F, or Form 2106 or Form 2106-EZ; and

Sec. 1 2001–1 I.R.B. 83 January 2, 2001

(4) Tax Exempt and Government Entities Division (TE/GE), which serves three distinct taxpayer segments: employee plans, exempt organizations, and government entities.

Description of terms used in For purposes of this revenue procedure– this revenue procedure

(1) any reference to director or field office refers to the Director, Field Operations, LMSB, the Area Director, Field Compliance, SB/SE, or the Director, Compliance, W&I, as appropriate, and their respective offices or, when appropriate, the Director, International, LMSB, the Director, Employee Plans Examinations, the Director, Exempt Organizations Examinations, the Director, Federal, State & Local Governments, the Director, Tax Exempt Bonds, or the Director, Indian Tribal Governments, and their respective offices;

(2) any reference to area director, appeals, refers to the Area Director, Appeals LMSB, or the Area Director, Appeals SB/SE-TE/GE, as appropriate;

(3) any reference to territory manager refers to a territory manager, LMSB, a territory manager, compliance, SB/SE, as appropriate, and, includes, when appropriate, the Employee Plans Examinations Area manager, the Exempt Organizations Examinations Area manager, the Employee Plans Determinations manager, the Exempt Organizations Determinations manager, the group manager, Federal, State & Local Governments, the manager, field operations, Tax Exempt Bonds, or the group manager, Indian Tribal Governments;

(4) any reference to area office refers to Appeals LMSB Area Office or Appeals SB/SETE/GE Area Office, as appropriate;

(5) any reference to appeals officer includes, when appropriate, the appeals team case leader;

(6) the term “taxpayer” includes all persons subject to any provision of the Internal Revenue Code (including issuers of § 103 obligations) and, when appropriate, their representatives; and

(7) the term “national office” refers to the Office of Associate Chief Counsel (Corporate), the Office of Associate Chief Counsel (Financial Institutions & Products), the Office of Associate Chief Counsel (Income Tax & Accounting), the Office of Associate Chief Counsel (International), the Office of Associate Chief Counsel (Passthroughs & Special Industries), the Office of Associate Chief Counsel (Procedure and Administration), or the Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities), as appropriate.

Updated annually The revenue procedure is updated annually as the second revenue procedure of the year, but may be modified or amplified during the year.