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Tax Law Research  

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

Field Service Advice Print Page
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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. 

Authoritative Value:

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:

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