SECTION 1. PURPOSE

This revenue procedure provides for a pilot program that will test whether the process for issuing Technical Advice Memoranda (TAMs) can be streamlined. The new advice will be known as a Technical Expedited Advice Memorandum (TEAM). During the TEAM pilot program, only issues under the jurisdiction of the Associate Chief Counsel (Income Tax & Accounting) will be eligible for a TEAM.

The purpose of the new TEAM pilot program is to expedite certain aspects of the TAM process and to eliminate certain requirements (taxpayer and field agreement on facts) that may delay or frustrate the process. Accordingly, the Office of Chief Counsel will provide an answer even if the taxpayer and the field disagree on the facts. The Office of Chief Counsel, in appropriate circumstances, may issue two separate answers: one based on the field’s factual submission and the other based on the taxpayer’s.

If the TEAM pilot program is successful, the Office of Chief Counsel expects to expand it to cover other types of issues and all Associate offices. The program also may be made permanent in Rev. Proc. 2003–2 or a subsequent annual revenue procedure. To that end, comments from taxpayers and practitioners regarding the TEAM pilot program are solicited and may be mailed to:

Internal Revenue Service CC:ITA:RU (RP–124153–02) Room 5226 POB 7604 Ben Franklin Station Washington, DC 20044 Attn: A. Lawan Jackson

Submissions may also be delivered Monday through Friday between the hours of 8 a.m. and 5 p.m to CC:ITA:RU (RP–124153–02), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC. Alternatively, taxpayers may submit comments electronically by submitting comments directly to the following IRS e-mail address: Notice.Comments@irscounsel. treas.gov .