SECTION 9. WHEN SHOULD

A TAM OR A TEAM BE REQUESTED?

Uniformity of position lacking or unusual or complex issue

When a TAM or a TEAM can be requested

a written or oral request to the examining agent or appeals officer that the issue be referred to the national office for a TEAM may be made.

.04 If, after considering a request 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 request reconsideration of the denial through the appropriate supervisory chain.

.01 A TAM or a TEAM should be requested when there is a lack of uniformity regarding the disposition of an issue or when an issue is unusual or complex enough to warrant consideration by the national office.

.02 The provisions of this revenue procedure apply only to a case under the jurisdiction of a director or an area director, appeals. A TAM or a TEAM may also be requested on issues considered in a prior appeals disposition, not based on mutual concessions for the same tax period of the same taxpayer, if the area office that had the case concurs in the request.

At the earliest possible stage .03 Once an issue is identified, all requests for a TAM or a TEAM should be made at the earliest possible stage in any proceeding. The fact that the issue is raised late in the examination or appeals process should not influence the field or area office’s decision to request a TAM or a TEAM.

Taxpayer participation not required