SECTION 14. HOW MAY

RETROACTIVE EFFECT BE LIMITED?

Requests for relief under § 7805(b)

.01 A taxpayer with respect to whom a TAM is issued or for whom a TAM request is pending may request that the appropriate Associate Chief Counsel limit the retroactive effect of any holding in the TAM or of any subsequent modification or revocation of the TAM. For a pending request for technical advice, the taxpayer should make the request for relief under § 7805(b) as part of the initial request for advice. The Associate office will consider a request for relief under § 7805(b) made at a later time if the Director determines that there is justification for the delay

Sec. 14.01 January 2, 2015 124 Bulletin No. 2015–1

Form of request for relief

– in general

Form of request for relief

– continuing transaction before examination of return

Taxpayer’s right to a conference

Reconsideration of request for relief under § 7805(b)

SECTION 15. SIGNIFICANT CHANGES MADE TO REV. PROC. 2014–2