SECTION 11. HOW ARE

REQUESTS HANDLED?

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January 7, 2002 174 2002–1 I.R.B.

.02 Conference offered

.03 If the taxpayer disagrees with the Service’s statement of facts

.04 If the Service disagrees with the taxpayer’s statement of facts

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

.06 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 EP or EO Examinations Area manager or EP or EO Determinations manager or the applicable Appeals office determines whether technical advice will be sought

.04 Decision may be reviewed but not appealed

.01 Taxpayer notified

.02 EP or EO Technical 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 may 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 Conference may 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

.01 Taxpayer or the taxpayer’s representative may request status from the EP or EO Examinations or the EP or EO Determinations or the appeals office

.02 EP or EO Technical will give status updates to the EP or EO Examinations or the EP or EO Determinations or the applicable Appeals Area Director

.01 Delegates authority to group managers

.02 Determines whether request has been properly made