SECTION 5. PROCEDURE FOR

APPEALING A PROPOSED ASSESSMENT AND REQUESTING AN APPEALS CONFERENCE

.01 Small Case Appeals . If the proposed penalty assessment for any tax period is $25,000 or less, the taxpayer may appeal the proposed assessment by completing and submitting in writing two copies of a small case appeal request. The request should be mailed to the attention of the IRS officer or employee named on the notice of proposed assessment as the “Person to Contact” at the address shown on the front of the notice. The request must include the following:

(1) A copy of the notice of proposed assessment or the date and number of the notice and the taxpayer’s name and social security number, along with any information that will help the Service locate the taxpayer’s file;

(2) A statement that the taxpayer is requesting an Appeals conference; and

June 13, 2005 1234 2005–24 I.R.B.

director’s satisfaction that unusual circumstances merit consideration of such a claim. If the compliance area director decides not to consider a taxpayer’s abatement claim, the taxpayer will be notified of that decision.

.03 Only Appeals may consider a claim for abatement if the assessment was made on the basis of a decision of Appeals. If the assessment was made based on a decision of Appeals, the area director will forward the claim to Appeals for consideration. The taxpayer will be notified if Appeals decides not to consider a taxpayer’s abatement claim.