SECTION 1. PURPOSE

AND AUTHORITY

Description of purpose .01 Technical advice. This revenue procedure explains when and how the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting), the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs and Special Industries), the Associate Chief Counsel (Procedure and Administration), and the Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities) provide technical advice memoranda (TAMs) to a Director or an Appeals Area Director. It also explains the rights that a taxpayer has when a field office requests a TAM regarding a tax matter. Rev. Proc. 2013–2 superseded.

Updated annually .02 This revenue procedure is updated annually as the second revenue procedure of the year, but may be modified during the year.

Delegation authority .03 The provisions of this revenue procedure apply if the authority normally exercised by the Director has been properly delegated to another official.

SECTION 2. DEFINITIONS

Operating division .01 The term “operating division” means the (1) Large Business & International Division (LB&I); (2) the Small Business/Self-Employed Division (SB/SE); (3) the Wage and Investment Division (W&I); and (4) the Tax Exempt and Government Entities Division (TE/GE).

Director .02 The term “Director” means (1) the Director, Field Operations (LB&I) for the taxpayer’s industry; (2) a Territory Manager, Field Compliance (SB/SE); (3) the Director, Compliance (W&I); (4) the Director, International Compliance, Strategy and Policy; (5) the Director, Employee Plans Examinations; (6) the Director, Exempt Organizations Examinations; (7) the Director, Federal, State & Local Governments; (8) the Director, Tax Exempt Bonds; (9) the Director, Indian Tribal Governments; (10) the Appeals Area Director;

Sec. 2.02 January 2, 2014 92 Bulletin No. 2014–1

(11) the Appeals Director, Domestic Operations, (12) the Appeals Director, International Operations; or (13) any official to whom the authority normally exercised by a Director has properly been delegated.

Territory Manager .03 The term “Territory Manager” means (1) a Territory Manager (LB&I); (2) a Territory Manager, Examination (SB/SE); (3) a Territory Manager, Specialty (SB/SE); (4) the Director, Compliance (W&I); (5) the Employee Plans Examinations Area Manager; (6) the Exempt Organizations Examinations Area Manager; (7) the Employee Plans Determinations Manager; (8) the Exempt Organizations Determinations Manager; (9) the Group Manager, Federal, State & Local Governments; (10) program managers within Tax Exempt Bonds; (11) the Manager, Field Operations, Tax Exempt Bonds; or (12) the Group Manager, Indian Tribal Governments.

Appeals officer .04 The term “Appeals officer” means the Appeals officer assigned to the taxpayer’s case and includes an Appeals Team Case Leader or settlement officer.

Taxpayer .05 The term “taxpayer” means any person subject to any provision of the Internal Revenue Code, including an issuer of obligations the interest on which is excluded from gross income under§103, issuers of other bonds that provided a tax subsidy, and the taxpayer’s representatives.

Associate office .06 The term “Associate office” means (1) the Office of Associate Chief Counsel (Corporate); (2) the Office of Associate Chief Counsel (Financial Institutions and Products); (3) the Office of Associate Chief Counsel (Income Tax and Accounting); (4) the Office of Associate Chief Counsel (International); (5) the Office of Associate Chief Counsel (Passthroughs and Special Industries); (6) the Office of Associate Chief Counsel (Procedure and Administration); or (7) the Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities).

Field office .07 The term “field office” means personnel in any examination or Appeals office.

Field counsel .08 The term “field counsel” means any attorney assigned to the Division Counsel for an operating division who is not a member of Division Counsel Headquarters.