The IRS has released IR-2006-38: IRS Encourages Businesses to Submit Tax Issues for Resolution Program:

Business taxpayers and associations may seek resolution of problematic tax issues through the IRS’s Industry Issue Resolution (IIR) Program. Submissions received by March 31, 2006, of business tax issues where the tax treatment is uncertain, frequently disputed or burdensome will be considered for IIR project selection and inclusion in the 2006-2007 Treasury and IRS Guidance Priority List.

The objective of the IIR program is to resolve business tax issues common to significant numbers of taxpayers through new guidance. In past years, issues have been submitted by associations and others representing both small and large business taxpayers, resulting in tax guidance that has affected thousands of business taxpayers engaged in a variety of industries….

For each issue selected, an IIR team of IRS and Treasury personnel gather relevant facts from taxpayers or other interested parties affected by the issue. The goal is to recommend guidance to resolve the issue. This benefits both taxpayers and the IRS by saving time and expense that would otherwise be expended on resolving the issue through examinations. The IRS reviews submissions semi-annually, after March 31 and August 31 of each year.