SECTION 2. BACKGROUND

.01. In Notice 2000–65, 2000–2 C.B. 599, the IRS announced the Industry Issue Resolution Pilot Program. The objective of the pilot program was to establish a procedure to address through pre-filing guidance rather than post-filing examination frequently disputed tax issues that are common to a significant number of large or mid-size business taxpayers. After evaluating the success of the pilot program, the IRS announced in Notice 2002–20, 2002–1 C.B. 732, that the IIR Program would be made permanent. In addition, Notice 2002–20 expanded the IIR Program to address issues common to small businesses, as well as large and mid-size businesses, and to address opportunities to reduce burden for all business taxpayers.

.02. Revenue Procedure 2003–36, 2003–1 C.B. 859, superseded Notice 2002–20 and revised procedures for business taxpayers, industry associations, and other interested parties to allow issues to be submitted at any time for consideration under the IIR Program. Revenue Procedure 2003–36 limited IIR Program submissions to taxpayers under the jurisdiction of the LB&I (formerly Large and Mid-Size Business) and SB/SE Operating Divisions.

.03. This revenue procedure supersedes Revenue Procedure 2003–36, 2003–1 C.B. 859. It expands the availability of the IIR Program to issues with respect to en

tities under the jurisdiction of the TE/GE Operating Division, and updates, revises, and clarifies the procedures.