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Rev. Proc. 2008-40, 2008–29 I.R.B. 151.

SECTION 13. HOW ARE

Internal Revenue Bulletin 2010-1 · 2026-10-03 edition · updated 2026-10-04 · United States

REQUESTS FOR TAMS WITHDRAWN?

Taxpayer notified .01 Once a request for a TAM has been sent to EP or EO Technical, only an EP or EO Examinations Area manager, an EP or EO Determinations manager or the Appeals Area Director may withdraw that request for the TAM. He or she may ask to withdraw a request at any time before the responding transmittal memorandum transmitting the TAM is signed.

The EP or EO Examinations Area manager, the EP or EO Determinations manager or the Appeals Area Director as appropriate, must notify the taxpayer in writing of an intent to withdraw the request for the TAM except—

(1) when the period of limitations on assessment is about to expire and the taxpayer has declined to sign a consent to extend the period, or

(2) when such notification would be prejudicial to the best interests of the Government.

If the taxpayer does not agree that the request for a TAM should be withdrawn, the procedures in section 12 of this revenue procedure must be followed.

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