Private Letter Rulings - Technical Advice Memorandums
Chief Counsel Advice
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Private Letter Rulings (PLR) or determinations are written memoranda
furnished by the IRS National Office in response to requests by taxpayers
under published annual guidelines. Technical Advice Memoranda (TAM) are
written memoranda furnished by the National Office of the IRS upon request
of a district director or chief appeals officer pursuant to annual review
procedures. Chief Counsel Advice (CCA) are written advice or instructions
prepared by the Office of Chief Counsel and issued to field or service
center employees of the IRS or Office of Chief Counsel.
It is important to note that pursuant to 26 USC § 6110(j)(3), such items
cannot be used or cited as precedent.
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