SECTION 11. HOW ARE

REQUESTS HANDLED?

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2002–1 I.R.B 83 January 7, 2002

.05 If the interpretation of a foreign law or foreign document is a material fact

.06 If the taxpayer has not submitted the required deletions statement

.07 Section 6104 of the Internal Revenue Code (Applications for exemption and letter rulings issued to certain exempt organizations open to public inspection)

.08 Criminal or civil fraud cases

.01 Taxpayer notified of decision not to seek technical advice

.02 Taxpayer may appeal decision not to seek technical advice

.03 Territory manager or area director, appeals, determines whether technical advice will be sought

.04 Territory manager’s or area director, appeals’, decision may be reviewed but not appealed

.05 Special procedures applicable to appeals regarding frivolous issues

.01 Taxpayer notified

.02 National office may provide views

.01 If requested, offered to the taxpayer when adverse technical advice proposed

.02 Normally held within 21 days of contact with the taxpayer

.03 21-day period will be extended if justified and approved

.04 Denial of extension cannot be appealed

.05 Entitled to one conference of right

.06 Conference may not be taped

.07 If requested and approved, conference will be delayed to address a request for relief under § 7805(b)

.08 Service makes tentative recommendations

.09 Additional conferences may be offered

.10 Additional information submitted after the conference

.11 Under limited circumstances, may schedule a conference to be held by telephone