Where to Submit Issues for IIR Program 

Consideration

By e-mail:

IIR@irs.gov

By FAX:

Industry Issue Resolution Program

Internal Revenue Service

Offi ce of Pre-fi ling and Technical Services

202-283-8406

By Mail:

Industry Issue Resolution Program

Internal Revenue Service

Offi ce of Pre-fi ling and Technical Services

Large and Mid-Size Business Division

Mint Building 3rd Floor M3-420

1111 Constitution Avenue NW

Washington, DC 20224

For More Information:

Check the IRS Web Page at:

www.irs.gov

Under “contents,” select “Businesses”

Select “Industry Issue Resolution Program”

Access the Revenue Procedure:

Revenue Procedure 2003-36

RP-03-36, Internal Revenue Bulletin 2003-18

May 5, 2003

www.irs.gov/pub/irs-utl/rev_proc_2003-36.pdf

Contact your local offi ce of Taxpayer 

Education and Communication, Small 

Business/Self-Employed:

Garden City, NY 516-683-5171

Birmingham, AL 205-912-5363

St. Paul, MN 651-312-7769

Denver, CO 303-446-1412

Oakland, CA 510-637-2193

or

Contact the Offi ce of Pre-Filing & Technical 

Services, Large and Mid-Size Business:

Washington D.C. 202-283-8414

Industry 

Issue

Resolution

Program

Industry 

Issue

Resolution

Program

Internal

Revenue

Service
About the Program

The Industry Issue Resolution (IIR) Program offers 

taxpayers, industry associations and other parties 

an opportunity to submit frequently disputed or 

burdensome business tax issues for possible resolution 

through published or administrative guidance.

Resolution of contentious or burdensome issues prior 

to fi ling tax returns benefi ts both taxpayers and the 

Internal Revenue Service. Time and expenses are saved 

that would otherwise be expended on resolving issues 

through the audit process.

The Large and Mid-Size Business (LMSB), the Small 

Business and Self Employed (SB/SE) Divisions, 

Appeals, the Offi ce of Chief Counsel and the Department 

of Treasury evaluate issues submitted and identify 

a limited number of issues for inclusion in the IIR 

Program each year. 

For each issue selected, an IIR team consisting of IRS 

and Treasury personnel meets with taxpayers or other 

interested parties to obtain a better understanding 

of the issue. Resulting guidance may be in the form 

of a revenue ruling, revenue procedure, notice or 

administrative guidance.

Examples of guidance issued under the IIR Program 

include standard rates for meals provided by family day 

care providers and depreciation rules for golf course 

land improvements and gasoline pump canopies.

Issues Appropriate for the IIR Program 

• The proper tax treatment of a common factual situation is 

uncertain.

• The uncertainty results in frequent, and often repetitive, 

examinations of the same issue.

• The uncertainty results in taxpayer burden.

• The issue is signifi cant and impacts a large number of 

taxpayers, whether within an industry or across industry 

lines.

• The issue requires extensive factual development, and an 

understanding of industry practices and views concerning 

the issue would assist the Service in determining the 

proper tax treatment.

Issues Not Appropriate for the Program

• Issues unique to one or a small number of taxpayers.

• Issues that are primarily under the jurisdiction of Operating 

Divisions of the IRS other than the LMSB and SB/SE 

Divisions.

• Issues that involve transactions that lack a bona fi de 

business purpose, or transactions with a signifi cant 

purpose of improperly reducing or avoiding federal taxes.

• Issues that involve transfer pricing or international tax 

treaties.

Submitting an Issue

There is no required format for submitting a request for 

consideration. The submission should, however, include:

• A statement of the issue;

• A description of why the issue is appropriate for the 

IIR Program;

• An explanation of the need for guidance;

• The estimated number of taxpayers affected by the 

issue;

• A recommendation as to how the issue may be 

resolved, if known; and,

• The name and telephone number of a person to 

contact.

Disclosure of Information

A public announcement will be issued describing the issues 

reviewed and those selected for Council’s Guidance Priority 

List. Because all submissions made under the IIR Program 

will be made available for public inspection, submissions 

should not include confi dential or taxpayer specifi c 

information.

When to Submit

Interested parties may submit issues at any time during the 

year. The LMSB and SB/SE Divisions will evaluate the 

issues submitted semi-annually, generally after March 31 

and August 31 of each year.