Part III. Administrative, Procedural, and Miscellaneous
SECTION 17. WHAT
Internal Revenue Bulletin 2005-1 · 2026-10-03 edition · updated 2026-10-04 · United States
SIGNIFICANT CHANGES HAVE BEEN MADE TO REV. PROC. 2004–2?
In the event that multiple taxpayers will be affected by the advice ( e.g., subject matter of the request involves a transaction between multiple taxpayers), the Associate office can issue a single TAM or TEAM, but only if each taxpayer agrees to participate in the process. (section 1.03)
A director may not request a TAM or a TEAM for any issue that is being litigated in a docketed case. (section 6.04)
The field office and the taxpayer are required to coordinate and share their statement of facts and issues prior to submitting materials to the Associate office for the pre-submission conference. (section 8.04)
Replies to requests for a TAM or a TEAM are addressed to the field personnel who requested it, and copies of replies are now addressed to director or the appeals area director. (section 12.13)
Sec. 16.03 January 3, 2005 114 2005–1 I.R.B.
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