SECTION 5. WHO IS RESPONSIBLE

FOR REQUESTING A TEAM?

Requests for a TEAM . A request for a TEAM can originate with the taxpayer, exam or appeals personnel, or field counsel. All requests for a TEAM must be submitted through the supervisory chain for exam or appeals and must be approved by the director or equivalent official in the respective operating divisions or by the area director, appeals (or by an official authorized to act on their behalf) before submission to the Associate. If the director or equivalent official declines to approve the request, then the denial can be appealed to the Division

Commissioner for that Operating Division or to the Deputy Director, General Appeals Programs or Director, Appeals, LBSP.

Taxpayer initiated request . While a case is under the jurisdiction of a director or area director, appeals, a taxpayer may make a written or oral request to the examining agent or appeals officer that an issue be referred to the Associate for a TEAM.

Field counsel initiated request . Exam or appeals personnel can request advice from field counsel on issues involved in cases under their jurisdiction. If, during the discussion of an issue with an examining agent or appeals officer, field counsel believes an issue warrants consideration as a TEAM, then field counsel may make a written or oral request to the examining agent or appeals officer that the issue be referred to the Associate for a TEAM.

Resolution of conflicts over requests for a TEAM . If, after considering a request by the taxpayer or field counsel that an issue be submitted for a TEAM, the examining agent or appeals officer disagrees with the request, the taxpayer or the field counsel may raise the request through the examining agent’s or the appeals officer’s supervisory chain.