SECTION 10. RECONSIDERATION

OF A TEAM

The field will have 30 calendar days from issuance to request reconsideration or the TEAM becomes final and will be released to the taxpayer, as is provided in section 17 of Rev. Proc. 2002–2. The request for reconsideration from the field must come from the director or area director, appeals. The request for reconsideration must describe with specificity the errors in the TEAM analysis and conclusions. Requests for reconsideration should not reargue points raised in the initial request, but should instead focus on points that the TEAM overlooked or misconstrued in the field’s arguments in support of their request.

The Associate will consider the field’s request for reconsideration and rule on that request within 30 calendar days of receipt. The Associate may request further submissions from the field or the taxpayer, but no additional submissions shall be made in the absence of such a request. If the field does not request reconsideration, the TEAM will take effect at the end

June 17, 2002 1186 2002–24 I.R.B.

of the 30-day period following the issuance of the TEAM to the field. If reconsideration is requested, the TEAM will take effect 5 calendar days after the reconsideration is ruled on.

In the event of a TEAM adverse to the taxpayer, in whole or in part, the taxpayer may request section 7805(b) relief. Such a request will be treated as a separate request subject to the user fee requirements in Rev. Proc. 2002–1. (Similar to section 301.9100 relief.)