When more than one Branch has taken an adverse position on an issue within its jurisdiction, or when the position ultimately adopted by one Branch will affect another Branchs determination, a representative from each Branch with authority to sign for the Branch Chief will attend the conference. In general, if the taxpayer, field or area office, field counsel, and the Associate office all agree, any issue eligible for a technical advice memorandum can be submitted for a technical expedited advice memorandum. If the request does not comply with CCDM 33.2.1.10.2, Section 6110 Procedures Applicable to Issuing Technical Advice and Technical Expedited Advice Issuance, relating to the statement of proposed deletions, the Associate office will make the deletions from the technical advice memorandum or the technical expedited advice memorandum required by IRC 6110(c). However, in Technical Advice Memorandum 9853002, the IRS ruled that married individuals are not treated as one person in calculating the $5 million threshold. If so informed, the taxpayer may submit within ten calendar days any further information, arguments, or other material to support the position that the material should be deleted. The technical advice memorandum or technical expedited advice memorandum provides alternate responses based on separate sets of facts, in which case the field must process the cases consistently with the legal analysis in the advice as applied to the facts ultimately determined by the field or area office. The requesting office must provide a copy to the field counsel involved in the case. Tech.Adv.Mem. In all cases, the Associate office attorney will inform the Examining agent or the Appeals Officer of the Associate Chief Counsels final conclusion(s). a. Wagering Tax (Taxable v. Not Taxable). TR 32-153-91 is an agreement with the IRS that excludable compensation is the same as workmen's comp. A E. All of these are administrative sources Technical Advice Memorandum 9645002 Code Sections 162 and 263 ISSUE Are "Pre-opening Costs," as defined below, associated with opening new stores required to be capitalized under 263 of the Internal Revenue Code? Technical Advice Memorandum. Requests for extensions should be justified by compelling facts and circumstances. Where a request for technical advice or technical expedited advice is received without a deletion statement from the taxpayer, the Associate office will make those deletions that in its judgment are required by section 6110(c). The Associate office attorney gives his or her name and office telephone number for future reference and then informs the requesting office that: The case is being returned because substantial additional information is required to resolve an issue, because significant unresolved factual variances exist between the statement of facts submitted by the requesting office and the taxpayer, or because major procedural problems cannot be resolved by telephone. Senior Tax Associate (Relocation & Work Permitting Covered)