SECTION 19. HOW ARE

CONFERENCES FOR TEAMs SCHEDULED?

Held within 30 calendar days of receipt of request

ing a conference with an official higher than the branch level. Section 18.02 of this revenue procedure also provides that other Service representatives are allowed to participate in the conference.

.10 In the case of a TAM, within 21 calendar days after the conference, the taxpayer must furnish to the national office any additional data, lines of reasoning, precedents, etc., that the taxpayer proposed and discussed at the conference but did not previously or adequately present in writing. This additional information must be submitted by letter with a penalties of perjury statement in the form described in section 21.11(2) of this revenue procedure. See section 19.05 of this revenue procedure for the procedures for submitting additional information after a TEAM conference.

For TAMs and TEAMs, the taxpayer must also send a copy of the additional information to the director or the area director, appeals for comment. Any comments by the director or the area director, appeals must be furnished promptly to the appropriate branch in the national office. If the director or the area director, appeals does not have any comments, he or she must notify the branch representative promptly.

If the additional information has a significant impact on the facts in the request for a TAM or a TEAM, the national office will ask the director or the area director, appeals for comment on the facts contained in the additional information submitted. The director or the area director, appeals will give the additional information prompt attention.

In the case of a TAM, if the additional information is not received within 21 calendar days, the TAM will be issued on the basis of the existing record. As discussed in section 19.05 of this revenue procedure, in the case of a TEAM, if the additional information is not received within 15 calendar days, the TEAM will be issued on the basis of the existing record.

An extension of the 21-day period for TAMs may be granted only if the taxpayer justifies it in writing and the associate chief counsel of the office to which the case is assigned approves the extension. Such extension will not be routinely granted. The procedures for requesting an extension of the 21-day period and notifying the taxpayer of the Service’s decision are the same as those in section 18.03 of this revenue procedure. As discussed in section 19.05 of this revenue procedure, there is no extension of the 15-day period for TEAMs.

.11 Taxpayers may request that their TAM conference of right be held by telephone. This request may occur, for example, when a taxpayer wants a conference of right but believes that the issue involved does not warrant incurring the expense of traveling to Washington, D.C. If the request is approved, the taxpayer will be advised when to call the Service representatives (not a toll-free call). As discussed in section 19.02 of this revenue procedure, TEAM conferences of right are normally conducted by telephone.

In accordance with section 18.02 of this revenue procedure, the examining officer or appeals officer will be offered the opportunity to participate in the TAM or TEAM telephone conference. Section 18.02 of this revenue procedure also provides that other Service representatives are allowed to participate in the conference.

In general, the procedures set forth in section 18 of this revenue procedure regarding conferences for TAMs apply to conferences for TEAMs, with the following modifications:

.01 Within 20 calendar days of receipt of the TEAM request, or, if later, within 5 calendar days after receiving additional information requested pursuant to section 21.11 of this revenue procedure, the assigned branch in the national office will analyze the facts and offer the taxpayer and the field a conference of right, which will be scheduled for a date within 10 calendar days of the date of the offer for the conference. No extension of the 10-day period will be allowed.

Sec. 19.01 2003–1 I.R.B. 99 January 6, 2003

Normally conducted by telephone

.02 The conference will be conducted by telephone, unless the taxpayer or the field requests that the conference be held in-person. In no event will the conference be delayed to provide an in-person conference rather than a telephone conference.

Held at the branch level .03 The conference will be held at the branch level and an individual with the authority to sign the transmittal memorandum (discussed in section 21.14 of this revenue procedure) in his or her own name or on behalf of the branch chief will participate.

No additional conferences are offered

Additional information submitted after the conference