For Tax Professionals  

Chief Counsel's
Written Determinations

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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