SECTION 14. HOW MAY

RETROACTIVE EFFECT BE LIMITED?

Request 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 in the making of the request. The Director’s determination that the delayed request for § 7805 is not justified cannot be appealed. Requests for relief under § 7805(b) relating to the revocation or modification

Bulletin No. 2023–1 139 January 3, 2023

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. 2022-2