SECTION 13. WHAT MUST BE

INCLUDED IN THE REQUEST FOR A TEAM?

In general, the same procedures set forth above in section 12 should be used for preparing a TEAM request that are used for preparing a TAM request, with the following modifications:

Factual statements .01 The field, with the assistance of field counsel, will prepare a factual statement. The taxpayer will have 10 calendar days to respond to the field’s statement. If the taxpayer and the field disagree over the statement, the parties will have 10 calendar days to attempt to resolve the disagreements. Within 5 calendar days of the expiration of the 10-day period or the day that factual agreement is reached, whichever is earliest, the TEAM request will be forwarded to the national office. If there is no agreement on the facts, both sets of facts will be forwarded to the national office. The field, with the assistance of field counsel, will prepare a memorandum for the national office highlighting the material factual differences, and provide a copy to the taxpayer. This memorandum will be forwarded with the initial request for a TEAM.

If there is no agreement on the facts, the taxpayer’s set of facts must be accompanied by the following declaration: “Under penalties of perjury, I declare that I have examined this information, including accompanying documents, and, to the best of my knowl- edge and belief, the information contains all the relevant facts relating to the request for the information, and such facts are true, correct, and complete.” This declaration must be signed in accordance with the requirements in section 8.01(15)(b) of Rev. Proc. 2003–1.

Submission of documents .02 To the extent feasible, documents must be electronically transmitted by field counsel (followed by hard copy upon the request of the assigned branch of the national office) to the CRU:TEAM e-mail address. Additional or supporting documents that are not available in electronic form should be sent by FAX to 202–622–3501 or by express mail or private delivery service to the following address to avoid any delays in regular mail:

Internal Revenue Service Attn: CC:PA:T:CRU, Room 6561 1111 Constitution Avenue, N.W. Washington, D.C. 20224

Sec. 13.02 2003–1 I.R.B. 91 January 6, 2003