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

SECTION 9. HOW

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

ARE PRE-SUBMISSION CONFERENCES SCHEDULED?

Pre-submission conference generally is permitted when a request for TAM is likely and all parties agree to request the conference

Purpose of pre-submission conference

.01 In an effort to promote expeditious processing of requests for a TAM, EP or EO Technical generally will discuss the issue(s) with the EP or EO Examinations or the EP or EO Determinations or the appeals office and the taxpayer prior to the time any request for technical advice is formally submitted to EP or EO Technical. In all cases, other than mandatory TAMs which are described in section 4.04, a pre-submission conference is mandatory.

A request for a pre-submission conference should be made, however, only after the EP or EO Examinations or the EP or EO Determinations or the appeals office determines that it will likely request a TAM.

If the request for a TAM will involve more than one function, representatives from each function involved must participate in the pre-submission conference.

.02 A pre-submission conference is intended to facilitate agreement between the parties as to the appropriate scope of the request for a TAM or any collateral issues that either should or should not be included in the request for a TAM, and any other substantive or procedural considerations that will allow EP or EO Technical to provide the parties with a TAM as expeditiously as possible.

Sec. 8 January 4, 2010 172 2010–1 I.R.B.

Request for pre-submission conference must be submitted in writing by the EP or EO Examinations or the EP or EO Determinations or the appeals office

Group will contact the EP or EO Examinations or the EP or EO Determinations or the appeals office to arrange the pre-submission conference

Pre-submission conference generally held by telephone

Certain information required to be submitted to EP or EO Technical prior to the pre-submission conference

Manner of submitting pre-submission materials

Pre-submission conference may not be taped

Discussion of substantive issues is not binding on the Service

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▸Contents — Internal Revenue Bulletin 2010-1
Internal Revenue Bulletin 2010-1

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