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ABA Tax Challenge Research Guide: IRS Guidance

Common Forms of IRS Guidance

Here are some common forms of IRS guidance:

Private Letter Ruling (P.L.R.) : fee-based written decision by the IRS in response to a specific individual’s request for guidance, as it relates to that individual’s specific situation. PLRs are only binding on the IRS and the requesting individual, and as such can not be cited as precedent for other cases, although they do give insight as to what the IRS’ position may be on a particular situation.  Not published in Internal Revenue Bulletin. These can be found in the following locations:

  • Library Lower Floor at KF 6282
  • IRS Written Determinations website
  • Legal Bitstream
  • Standard Federal Tax Reporter (CCH) In Library: Upper and Lower Floor, KF6285.C6S7. (Use Finding Lists/Devices volume at end of each year for locating cited documents.)
  • The Internal Revenue Bulletin
  • CCH Tax Compliance Library (Cheetah)

Revenue Rulings (Rev. Rul.): an official interpretation by the IRS of the Internal Revenue Code, related statutes, tax treaties and regulations. They are administrative rulings that explain how the IRS applies the law to specific factual situations.  These rulings are guidance for all taxpayers, and are published in the Internal Revenue Bulletin and the Federal Register. These can be found in the following locations:

  • The Internal Revenue Bulletin and Cumulative Bulletin
  • Standard Federal Tax Reporter (CCH)
  • Checkpoint RIA
  • Westlaw Edge
  • CCH Tax Compliance Library (Cheetah)
  • Legal Bitstream

Revenue Procedures (Rev. Proc): official statements of a procedure (rather than the application of law, as Rulings do) that affects the rights or duties of taxpayers or other members of the public under the Internal Revenue Code, related statutes, tax treaties and regulations and that should be a matter of public knowledge. Also published in the Internal Revenue Bulletin.  While a revenue ruling generally states an IRS position, a revenue procedure provides return filing or other instructions concerning an IRS position. These can be found in the following locations:

  • The Internal Revenue Bulletin and Cumulative Bulletin
  • Standard Federal Tax Reporter (CCH)
  • Westlaw Edge
  • CCH Tax Compliance Library (Cheetah)
  • Legal Bitstream

Technical Advice Memorandum ("TAM"): guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director, appeals, in response to technical or procedural questions that develop during a proceeding. A request for a TAM generally stems from an examination of a taxpayer's return, a consideration of a taxpayer's claim for a refund or credit, or any other matter involving a specific taxpayer under the jurisdiction of the territory manager or the area director, appeals. Technical Advice Memoranda are issued only on closed transactions and provide the interpretation of proper application of tax laws, tax treaties, regulations, revenue rulings or other precedents. The advice rendered represents a final determination of the position of the IRS, but only with respect to the specific issue in the specific case in which the advice is issued. These can be found in the following locations:

  • IRS Letter Rulings: print in Library at KF6301.A4 C6
  • IRS Written Determinations website
  • CCH Tax Compliance Library (Cheetah)
  • Checkpoint IRA

Notice: A notice is a public pronouncement that may contain guidance that involves substantive interpretations of the Internal Revenue Code or other provisions of the law. For example, notices can be used to relate what regulations will say in situations where the regulations may not be published in the immediate future.

Announcement: An announcement is a public pronouncement that has only immediate or short-term value. For example, announcements can be used to summarize the law or regulations without making any substantive interpretation; to state what regulations will say when they are certain to be published in the immediate future; or to notify taxpayers of the existence of an approaching deadline.

Notices and announcements can be found at the following locations:

  • The Internal Revenue Bulletin and Cumulative Bulletin
  • Standard Federal Tax Reporter (CCH)
  • Westlaw Edge and Lexis
  • CCH Tax Compliance Library (Cheetah)
  • Legal Bitstream
  • Checkpoint RIA

 


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