On October 16, 2020, TEI submitted comments to the Large Business & International Division of the IRS urging the division to retain Rev. Proc. 94-69 and extend it to all taxpayers subject to the Large Coordinated Case Program. The comment letter provides extensive discussion supporting TEI’s view that Rev. Proc. 94-69 is a critical simplifying procedure that simplifies audits, promotes transparency and collaboration between taxpayers and Exam teams, and provides a mechanism for resolving issues at the lowest possible level in examinations and that the reasons the IRS offered in support of eliminating the procedure reflected an overly simplistic view of the procedure, as well as the tax compliance burdens and other pressures unique to large case taxpayers.