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Last Updated: Aug 22, 2017 URL: http://libguides.law.usd.edu/taxlaw Print Guide RSS Updates

Technical Advice Memoranda Print Page
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What are Technical Advice Memoranda?

Technical Advice Memoranda (TAMs) are publicly available but are not officially published by the IRS.

They are taxpayer-specific.

"Technical Advice Memorandums (TAMs) are requested by IRS area offices after a return has been filed, often in conjunction with an ongoing examination" (IRM 4.10.7.2.10).  They are similar to private letter rulings, but whereas PLRs generally arise from a taxpayer's request for advice on a proposed transaction, TAMs arise from IRS employees' requests for advice regarding the examination of a tax return.

Authoritative Value:

"[A] technical advice memorandum to an area director, which relates to a particular case, should not be applied or relied upon as a precedent in the disposition of other cases. However, they provide insight with regard to the Service’s position on the law and serve as a guide" (IRM 4.10.7.2.10).

TAMs issued after October 31, 1976 may be used as substantial authority to avoid the substantial understatement penalty. 

Numbering:

TAMs share the same multiple digit file numbers with letter rulings, i.e. the first two digits indicating the year the TAM/Ruling was issued, the second two digits indicating the week of the year the TAM/Ruling was released, and the remaining numbers indicating the number of the item issued that particular week (e.g. T.A.M. 99-32-001 or P.L.R. 99-32-083).  TAMs carry the first release numbers for any particular week.  

 

How Do I Access Technical Advice Memoranda?

Free Electronic:

Electronic to Authorized Users:

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