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Introduction

SECTION 7. WHEN SHOULD

Internal Revenue Bulletin 2002-1 · 2026-10-03 edition · updated 2026-10-04 · United States

TECHNICAL ADVICE BE REQUESTED?

Uniformity of position lacking or unusual or complex issue

When technical advice can be requested

.01 Technical advice should be requested when there is a lack of uniformity regarding the disposition of an issue or when an issue is unusual or complex enough to warrant consideration by the national office.

.02 The provisions of this revenue procedure apply only to a case under the jurisdiction of a director or an area director, appeals. Technical advice may also be requested on issues considered in a prior appeals disposition, not based on mutual concessions for the same tax period of the same taxpayer, if the area office that had the case concurs in the request.

At the earliest possible stage .03 Once an issue is identified, all requests for technical advice should be made at the earliest possible stage in any proceeding. The fact that the issue is raised late in the examination or appeals process should not influence, however, the field or area office’s decision to request technical advice.

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▸Contents — Internal Revenue Bulletin 2002-1
Internal Revenue Bulletin 2002-1

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