“A Revenue Procedure is a statement of procedure that affects the rights or duties of taxpayers or other members of the public under the Code and related statutes or information that, although not necessarily affecting the rights and duties of the public, should be a matter of public knowledge.” 26 C.F.R. §601.601(d)(2)(i)(b)(2002). “Revenue Procedures usually reflect the contents of internal management documents, but, where appropriate, they are also published to announce practices and procedures for guidance of the public.” 26 C.F.R. §601.601(d)(2)(vi)(2002).
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