What are Field Service Advice Documents?
Field Service Advice (FSA) memoranda are publicly available but are not officially published by the IRS.
They are specific to a particular case.
FSAs are issued by the office of Chief Counsel to provide case-specific advice to field employees. However, FSAs have been phased out by the IRS.
FSAs do not represent a final determination of the IRS's position, even in the case for which they were issued. They should not be cited as precedent.
FSAs are not substantial authority for purposes of the substantial understatement penalty.
How Do I Access Field Service Advice Documents?
Electronic to Authorized Users:
- Via WestlawNext
- Via Bloomberg Law
- (From the Tax Practice Center, choose Regulatory Agencies and then search for the source)
- Via Lexis Advance
- Via RIA Checkpoint
- (From the main page, under Primary Source Materials, click the + next to IRS Rulings and Releases, and then choose Field Service Advice)
- Via the Bloomberg/BNA Tax and Accounting Center
- Via LexisNexis Academic
- Via CCH Intelliconnect