SECTION 3. DEFINITIONS

For purposes of this revenue procedure—

(1) The term “taxpayer” includes all persons subject to any provision of the Internal Revenue Code (including issuers of section 103 obligations) and, when appropriate, their representatives;

(2) The term “Associate” means the Associate Chief Counsel (Income Tax & Accounting);

(3) The term “field” refers to field counsel and exam and appeals personnel;

June 17, 2002 1184 2002–24 I.R.B.

Within 5 calendar days of receiving the request, the assigned branch within the Associate’s office will contact the field office to schedule the conference. The conference will be held within 15 calendar days of the assigned branch’s call to the field office and will be held by telephone, unless the parties specifically request a meeting in person. In no event will a request for an in-person presubmission conference be allowed to delay the conference beyond the 15-day period. The presubmission materials must be received by the assigned branch in the Associate’s office no later than 5 calendar days prior to the conference. In order to obtain the protection of taxpayer information offered by the Chief Counsel Intranet “firewall,” the presubmission materials shall be electronically transmitted by field counsel to the CRU-TEAM e-mail address. To the extent that supporting materials cannot reasonably be submitted, such materials should be sent by FAX, express mail, or private delivery service to avoid any delays in regular mail to the Associate’s office.

During the presubmission conference, the parties should determine whether the issue is appropriate for a TEAM, and how the issue should be framed. The participants from the Associate’s office will explain the TEAM procedures and the expedited time frames involved. If all parties agree that the TEAM process is desirable, then the request will be processed subject to the TEAM pilot procedures. The parties also should agree on the background documents necessary for the TEAM, and when and how the parties will submit those documents to the Associate.

If the parties do not agree that the TEAM process is appropriate for the issue, the standard TAM procedures of Rev. Proc. 2002–2 may be used.