The Associate Chief Counsel (or delegate) will promptly notify the taxpayer by telephone and later in writing of the approval or denial of the requested extension. Richter is a Business | Family Office that provides strategic advice on business matters and on families' financial and personal objectives across generations. The assigned Associate office attorney and reviewer should evaluate the issue in a technical advice or technical expedited advice request to determine whether published guidance is appropriate. Technical advice The conference must be held within 21 calendar days after the Associate office attorney and reviewer notify a taxpayer that an adverse technical advice memorandum is proposed. Tax Law Specialist (Technical Advisor) NTE 1 Year, MBE, 12 Month Roster Because the Associate office attorneys tentative conclusion may change during the preparation and levels of review of the technical advice memorandum or the technical expedited advice memorandum, it is not, under any circumstances, considered final. See Rev. If a taxpayer was not advised of a request for technical advice or technical expedited advice, as provided in CCDM 33.2.2.1.2(7), the taxpayer should not be contacted. Citations are to IRS private letter rulings, technical advice memoranda, gen-eral counsel memoranda, and chief counsel memoranda, other than . The taxpayer should be told the tentative conclusion only when scheduling the adverse conference, at the adverse conference, or in any discussion between the scheduling and commencement of the adverse conference; however, all discussions with the taxpayer should be undertaken with the understanding that if the final technical advice memorandum or technical expedited advice memorandum issued to the taxpayer is adverse, it may lead to litigation. A distribution copy of the reply to a request from the operating divisions should be mailed simultaneously to the field personnel who requested it under the signature authority of the director. While a revenue ruling generally states an IRS position, a revenue procedure provides return filing or other instructions concerning an IRS position.
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