Yes, Rev. Proc. 94-69 applies to Coordinated Examination Program (CEP) taxpayers, which are now referred to as Compliance Assurance Process (CAP) taxpayers. Rev. Proc. 94-69 provides procedures for CEP taxpayers to make adequate disclosures to avoid certain penalties. Specifically, it allows these taxpayers to submit a written statement disclosing items that might result in adjustments during an examination, thereby potentially avoiding penalties for underpayment due to negligence or disregard of rules or regulations.
Sources:
Rev. Proc. 94-67
Rev. Proc. 94-58
Rev. Proc. 99-49
Rev. Proc. 2015-13
Rev. Proc. 94-49
Rev. Proc. 94-74
Rev. Proc. 92-74
