SECTION 1. WHAT IS THE

PURPOSE OF THIS REVENUE PROCEDURE?

Operating divisions of the Internal Revenue Service

This revenue procedure explains when and how the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) issue technical advice memoranda (TAM) and technical expedited advice memoranda (TEAM) to a director or an area director, appeals. It also explains the rights a taxpayer has when a director or an area director, appeals requests a TAM or TEAM regarding a tax matter.

The Internal Revenue Service includes four operating divisions that are responsible for meeting the needs of the taxpayers they serve. These operating divisions are:

(1) Large and Mid-Size Business Division (LMSB), which generally serves corporations, S corporations, and partnerships with assets in excess of $10 million;

(2) Small Business/Self-Employed Division (SB/SE), which generally serves corporations, S corporations, and partnerships with assets less than or equal to $10 million; estates and trusts; individuals filing an individual federal income tax return with an accompanying Schedule C ( Profit or Loss from Business (Sole Proprietorship )), Schedule E ( Supplemen- tal Income and Loss ), or Schedule F ( Profit or Loss from Farming ), or Form 2106 ( Em- ployee Business Expenses ) or Form 2106–EZ ( Unreimbursed Employee Business Expenses ); and individuals with international tax returns;

(3) Wage and Investment Division (W&I), which generally serves individuals with wage and investment income only and with no international tax returns, filing an individual federal income tax return without an accompanying Schedule C, E, or F, or Form 2106 or Form 2106–EZ; and

(4) Tax Exempt and Government Entities Division (TE/GE), which generally serves three distinct taxpayer segments: employee plans, exempt organizations, and government entities.

Updated annually This revenue procedure is updated annually as the second revenue procedure of the year, but may be modified or amplified during the year.