SECTION 1. PURPOSE

The purpose of this revenue procedure is to amplify, update, and restate Rev. Proc. 94–68, 1994–2 C.B. 803, which provides Internal Revenue Service procedures with respect to the reopening of examinations under section 7605(b) of the Internal Revenue Code. This revenue procedure also describes when a case is deemed closed after examination by the Service, describes, by category, a non-exclusive list of contacts with taxpayers and other actions by the Service that are not examinations, inspections, or reopenings of closed cases, explains when a closed case may be reopened to make an adjustment unfavorable to the taxpayer, and explains who within the Service must approve a reopening.