SECTION 3. SCOPE

.01 Issues appropriate for the program. The issues most appropriate for consideration under the IIR Program generally will have two or more of the following characteristics:

(1) The proper tax treatment of a common factual situation is uncertain.

(2) The uncertainty results in frequent, and often repetitive, examinations of the same issue.

(3) The uncertainty results in taxpayer burden.

(4) The issue is significant and impacts a large number of taxpayers, either within an industry or across industry lines.

(5) The issue requires extensive factual development, and an understanding of industry practices and views concerning the issue would assist the Service in determining the proper tax treatment.

.02 Issues not appropriate for the pro- gram.

The following issues are not appropriate for consideration under the IIR Program:

(1) Issues that are unique to one or a small number of taxpayers.

(2) Issues that are primarily under the jurisdiction of Operating Divisions of the Service other than the LMSB and SB/SE Divisions.

(3) Issues that involve transactions that lack a bona fide business purpose, or transactions with a significant purpose of improperly reducing or avoiding federal taxes.

(4) Issues that involve transfer pricing or international tax treaties.