3.USAco is the wholly-owned United States subsidiary of ASIAco, a foreign corporation. USAco purchases automobiles from ASIAco for $20,000, and resells the automobiles for $21,000. The IRS conducts a transfer pricing examination of USAco and proposes an adjustment based on what it believes to be the arms length transfer price of $15,000. USAco decides to pursue the issue at both Appeals and Competent Authority under the Simultaneous Appeals Procedure (SAP). Describe the SAP procedures.