SECTION 1. PURPOSE

AND AUTHORITY

Description of purpose .01 Technical advice. This revenue procedure explains when and how an Associate office provides technical advice, conveyed in a technical advice memorandum (TAM). It also explains the rights that a taxpayer has when a field office requests a TAM regarding a tax matter. Rev. Proc. 2024-2 is superseded.

Updated annually

SECTION 2. DEFINITIONS

Operating division

.02 This revenue procedure is updated annually as the second revenue procedure of the year, but it may be modified, amplified, or clarified during the year.

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

Director .02 The term "Director" means (1) the Practice Area Director or the Director, Field Operations (LB&I) for the taxpayer's practice area; (2) an Area Director, SB/SE; (3) the Director, Return Integrity & Compliance Services (TS); (4) the Director, International Compliance, Strategy and Policy; (5) the Director, Employee Plans Examinations; (6) the Director, Employee Plans Rulings & Agreements; (7) the Director, Exempt Organizations Examinations; (8) the Director, Exempt Organizations Rulings & Agreements; (9) the Director, Government Entities; (10) the Appeals Area Director; (11) the Appeals Director, Technical Guidance; (12) the Appeals Director, International Operations; or (13) any official to whom the authority normally exercised by a Director has properly been delegated.

Appeals .03 The terms “Appeals” and “Appeals office” refer to the Internal Revenue Service Independent Office of Appeals.

December 30, 2024 120 Bulletin No. 2025–1

Appeals officer .04 The term "Appeals officer" means the Appeals officer assigned to the taxpayer’s case and can include 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, and issuers of other bonds that provide a tax benefit.

Associate office .06 The term "Associate office" means (1) the Office of Associate Chief Counsel (Corporate); (2) the Office of Associate Chief Counsel (Energy, Credits, and Excise Tax); (3) the Office of Associate Chief Counsel (Financial Institutions and Products); (4) the Office of Associate Chief Counsel (Income Tax and Accounting); (5) the Office of Associate Chief Counsel (International); (6) the Office of Associate Chief Counsel (Passthroughs, Trusts and Estates); (7) the Office of Associate Chief Counsel (Procedure and Administration); or (8) the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes).

Field office

Field counsel