SECTION 8. REQUEST FOR THE

COMMISSIONER TO DESIGNATE AN AGENT UNDER § 1.1502–77(c)(6)

.01 In general . Any written request to the Commissioner to designate an agent pursuant to § 1.1502–77(c)(6) should be made in the manner prescribed in this section 8. Such request may (but is not required to) propose a member (or a successor of a member) for the Commissioner to designate as agent.

.02 When to file . A request that the Commissioner designate an agent under § 1.1502–77(c)(6)(i)(A)( 1 ) may be filed at any time after the agent’s existence terminates and before the Commissioner designates an agent in the manner prescribed in section 10.02 of this revenue procedure. Other written requests that the Commissioner designate another agent under § 1.1502–77(c)(6) can be filed at any time.

.03 Contents . A request for designation of an agent must be in writing and contain the following information:

(1) The heading “REV. PROC. 2015– 26: REQUEST FOR DESIGNATION OF AGENT UNDER § 1.1502–77(c)(6)” must be typed or legibly printed at the top of the designation;

(2) Name, address, and employer identification number of the agent to be replaced;

(3) Name, address, and employer identification number of the proposed agent, if any, and the consolidated return year(s) for which the designation is requested;

(4) The name and employer identification number of the common parent under which the return(s) for which the designation is requested was (were) filed, if different from the agent named in section 8.03(2) of this revenue procedure; (5) The Service Center where the consolidated return(s) was (were) or will be filed, as the case may be, for the year(s) for which the designation is requested;

(6) If relevant, the date the agent’s existence terminated and the circumstances under which it terminated (for example, dissolution under state law or merger into a limited liability company) or the date that the agent ceased (or will cease) to be a member of the group and the circumstances under which it ceased (or will cease) to be a member of the group;

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(7) The reason for the written request for the Commissioner to designate an agent;

(8) The name and address of the corporation(s) (or other person(s)) that has (have) custody of the books and records with respect to the consolidated return year(s) for which the designation is requested, if different from any proposed agent named in section 8.03(3) of this revenue procedure, and if so, a description of the arrangements available to the proposed agent for access to the books and records; and

(9) The name, address, and phone number of the Examination Team Manager, Appeals Officer or Counsel Attorney, if any, who currently has jurisdiction of the consolidated return year(s) for which the designation is requested.

.04 Signature requirement . A request under this section 8 must contain the following declaration, signed by a duly authorized officer of at least one of the requesting members that was a member of the group for the consolidated return year(s) for which the designation is requested: Under penal- ties of perjury, I declare that I am autho- rized to make this request on behalf of the named member of the group and that, to the best of my knowledge, the information provided is true, correct, and complete.

.05 Designation by the Commissioner . (1) In response to a request under this section 8, the Commissioner may, in the Commissioner’s sole discretion, designate as the agent the member (or successor of the member) proposed by the request, if any, or another member (or successor of another member). In determining whether to make the requested designation, the Commissioner may request information from, or communicate information relating to the designation request to, any member of the group. Thus, for example, in the case of a request by a member that the Commissioner designate another agent to replace the existing agent of a group, the Commissioner may request information from, or communicate information to, the agent the request seeks to replace.

(2) The Commissioner will notify any designated agent by providing the notice described in section 10.02 of this revenue procedure.