SECTION 7. WHO IS

RESPONSIBLE FOR REQUESTING TECHNICAL ADVICE?

EP or EO Examinations Area .01 The EP or EO Examinations Area manager, the EP or EO Determinations manager manager or EP or EO or the Appeals Area Director, SB/SE-TE/GE, determines whether to request technical Determinations manager or advice on any issue being considered. Each request must be submitted through proper Appeals Area Director, channels and signed by a person who is authorized to sign for the EP or EO Examinations SB/SE-TE/GE determines Area manager, the EP or EO Determinations manager or the Appeals Area Director, whether to request technical advice SB/SE-TE/GE. The mandatory technical advice described in section 4.04(3) of this revenue procedure, for cases concerning amendments to defined contribution plans in connection with a waiver of the minimum funding standard and a request for a determination letter, is treated as if it had been a request for technical advice submitted by the EP Determinations manager. See section 15 of Rev. Proc. 2001–6 and section 3.04 of Rev. Proc. 94–41 for the procedural rules applicable to this particular mandatory technical advice.

Taxpayer may ask that issue .02 While a case is under the jurisdiction of EP or EO Examinations, EP or EO be referred for technical advice Determinations, or an Appeals Area Director, SB/SE-TE/GE, a taxpayer may request that an issue be referred to the EP or EO Technical office for technical advice.