This section does not include instructions on processing unagreed cases to Appeals, but covers only those cases which may be forwarded for technical advice. For additional information on Appeals procedures, see IRM Part 8. Section 2 of the revenue procedure specifies the significant changes made to the prior year's revenue procedure. Exhibit 7.9.4-1 lists the Appeals offices with jurisdiction over EP cases. Where technical advice is adverse to the applicant, no further appeal is allowed within IRS on those issues.
Local procedures provide specific procedures for requesting technical advice.
Appeals Procedures for unagreed cases are described in the appropriate Handbook for both EP and EO determination and examination programs. Issues Covered by Other Rev. Procs. The following issues are covered by other revenue procedures other than Rev. Proc. Any matter pertaining to either tax-exempt bonds or mortgage credit certificates. See Rev. Proc.