SECTION 6. DRAFTING

INFORMATION

The principal author of this revenue procedure is Carol B. Tan of the Office of Associate Chief Counsel (International). For further information regarding this revenue procedure, contact Ms. Tan at (202) 435–5265 (not a toll-free call).

(1) The taxpayer’s name, address, and U.S. employer identification number or Social Security number;

(2) The date and symbols on the 30-day letter or notice of deficiency specified in § 1.482–1(g)(4)(ii)(C) of the regulations and § 2.04 of this revenue procedure; and

(3) The taxable year(s) involved. .04 The taxpayer must include with the notification a signed declaration under penalties of perjury that the statements made in the notification, and all evidence submitted, are true, correct, and complete to the best of the taxpayer’s knowledge and belief.

.05 If a duly authorized representative prepares or files the notification, instead of the declaration required by § 3.04 of this revenue procedure, the representative may substitute a declaration stating that the representative:

(1) Prepared the notification and accompanying documents, and

(2) Knows personally that the statements contained therein and all evidence submitted are true, correct, and complete to the best of the representative’s knowledge and belief.

.06 An incomplete or improper notification will not extend the period within which the Commissioner is to be notified. Therefore, the taxpayer must be careful to include sufficient information in its notification and, if possible, to submit the notification in sufficient time to permit correction of any deficiencies within the prescribed limitation period. Thus, as indicated in § 2.04 of this revenue procedure, when possible, the notification should be submitted during the examination prior to the issuance of the 30-day letter.

.07 When appropriate, a previously submitted notification may be incorporated by reference into a protest filed by the taxpayer.

.08 To expedite the examination, information necessary to establish the claimed § 482 setoff must be submitted in accordance with § 2.05 of this revenue procedure.

.09 The taxpayer must make available to the Commissioner such information as the Commissioner may require to examine the transactions relied on by the taxpayer. In this connection, the taxpayer must execute such consents extending the statute of limitations as the Commissioner, in the exercise of the Commissioner’s administrative discretion, determines to be necessary to enable an examination of the transactions claimed by the taxpayer as § 482 setoffs. If the taxpayer declines to execute such consents, the Commissioner may reject the claimed § 482 setoffs.