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Food Industry Overview - Introduction


"This document is not an official pronouncement of the law or the position of the Service and cannot be used, or cited, or relied upon as such."

1. Introduction

A. Purpose of Industry Overview - This overview is designed to provide industry-related information to all Large Business & International (LB&I) Division.   This is a step in the effort of LB&I to develop a greater level of expertise in the industry or industries to which you will be assigned.   This overview is one of a series of industry specific overviews.  See the Appendix for a complete listing of available overviews.

B.  Use of the Intranet and Internet - Each Technical Advisor has established a web site on the LB&I Intranet.  These web sites contain more detailed information on each Technical Advisor area.  Topics that have been included in this Industry Guide are sometimes expanded upon and new topics may be added.  Each web site also has a “Hot Topics” section where Technical Advisors can highlight the latest developments such as new court cases, new technical advice memorandums, new revenue rulings, etc.  A section called “LB&I Forums” was also established.  Individuals will be able to write questions they have about various issues.  Others reading the question may be able to help you with your issue. 

C.  General History of Technical Advisor Program (TAP) formerly known as the Industry Specialization Forum (ISP)





The Service was restructured in 1952 into a highly decentralized organization consisting of seven regions and 58 districts.  This reorganization was implemented in part to achieve greater sensitivity and responsiveness to pubic needs.  District Directors were given wide latitude and authority in administering the Service's policies, procedures and programs.  While decentralization of the Service proved to be a progressive action, communication between the regions and districts was made more difficult because of their quasi‑autonomy.  Positions taken by the Service on industry issues could differ significantly from one region to another on the same issues.


The Service implemented the Industry Wide Examination Program to concurrently examine the major taxpayers in a given industry, coordinate selected issues common to that industry and to resolve those issues uniformly and consistently among all the industry taxpayers.  Under the direction of project coordinators (usually large case branch chiefs), the industry wide examinations were largely successful in achieving uniform and consistent treatment of issues.  Industry wide examinations were conducted in several industries between 1971 and 1979 and the ability to communicate freely across district and regional lines proved to be invaluable to the success of these examinations.


The Industry wide Examination Program had one major drawback.  Since they existed for only two or three tax years and were then terminated, the program failed to provide continuity.  To correct this situation, a major study group was created in 1977 to review the Service's Coordinated Examination Program.  The study recommended that permanent positions be established for several Industry Specialists and a National Industry Coordinator.  In addition, the study group identified basic industries to which it recommended specialists be assigned.  The duties and responsibilities of the Specialists and the Coordinator were to be much broader than the former Project Coordinators whom they replaced.


The recommendations of the study group were implemented greatly expanding the scope and depth of the Industry wide Examination Program.  The term, Industry Specialization Program, eventually evolved as a name that could encompass the varied concepts of Industry Specialists, National Industry Coordinator, Coordinated Issues, and the many refinements suggested by the study group.


As part of the Internal Revenue Service’s restructuring, the Industry Specialists were assigned to Pre-Filing and Technical Guidance which is part of LMSB, Headquarters.  The “Industry Specialists” are now called Technical Advisors.  Each of them was placed in one of the five industry areas and is managed by a Technical Advisor Manager.

D.  History of Food ISP




1984 - 1986

Conducted study of food industry, 55 cases in 7 regions included in the program study. 


Food industry approved for inclusion in ISP

1987 - 1992

Coordinated issue papers and appeals settlement guidelines developed.

E.  Industry Specialist Staffing (Technical Advisors in LB&I)


Name of Specialist

Telephone #


Philip Hofmann



F.  LB&I Industry Staffing - The Industry Specialist is assigned to the Pre-Filing and Technical Guidance Division that is a part of LB&I Headquarters.  Each industry is assigned to one of the five Industry Functional Divisions.  Industry Specialists will be known as technical advisors in LB&I and will be supervised by a Manager, Technical Advisors.  Information relative to the management in the Industry Division that this industry is assigned as well as the Manager: of the Technical Advisor(s) of this industry is as follows:






Sergio Arellano

Industry Director


Downers Grove, IL

Jim Roosey

Field Operations Director

Downers Grove, IL

Lori Nichols

Field Operations Director

Louisville, KY

Jessica Yip

Senior Industry Analyst

Downers Grove, IL

Greg Zielinski

Manager, Technical Advisors


St. Louis, MO

G.  Description of the Food Industry

The Food Industry program covers taxpayers involved in the manufacture and distribution of food, alcoholic beverages, non-alcoholic beverages and the restaurant industry.

The North American Industry Classification System (NAICS) has replaced the U.S. Standard Industrial Classification (SIC) system.    The major NAICS categories for the Food Industry are:

  • 311 Food Manufacturing
  • 312 Beverage Manufacturing
  • 445 Food and Beverage Stores
  • 722 Food Services and Drinking Places

This industry is also comprised of many sub-industries.  The following is a sample of the data for these sub-industries.   Information on each of these sub-industries is available on the Internet at:

  • 31123 Breakfast Cereal Manufacturing
  • 31141 Frozen Food Manufacturing
  • 31151 Dairy Product (except Frozen) Manufacturing
  • 31181 Bread and Bakery Product Manufacturing
  • 31211 Soft Drink and Ice Manufacturing
  • 31212 Breweries
  • 31214 Distilleries
  • 44511 Supermarkets and Other Grocery (except Convenience) Stores
  • 72211 Full-Service Restaurants
  • 72221 Limited-Service Eating Places
  • 72241 Drinking Places (Alcoholic Beverages)

The Food ISP also covers food brokers.   Not all food products are sold by brokers but there is significant activity. Typically, many of the food brokers are in SB/SE.

Table of Contents | Chapter 2

Page Last Reviewed or Updated: 05-Mar-2015