Chief Counsel Advice (CCA) are legal advisories written by the Chief Counsel's National Office to advise IRS personnel at all stages of case development. They convey legal interpretations or positions of the Office of Chief Counsel regarding existing or former revenue provisions.
"Chief Counsel advice is written advice or instruction prepared by any national office component of the Office of Chief Counsel that is issued to counsel or service field or Service campus employees which interprets or sets forth policy with respect to a revenue provision." Internal Revenue Manual 37.1.1.1.1 (4) (Aug. 11, 2004).
Chief Counsel Advice may include field service advice, technical assistance to the field, litigation guideline memoranda, tax litigation bulletins, general litigation bulletins, and criminal tax bulletins. See below for how to find different types of Chief Counsel Advice.
Field Service Advice (FSA) are responses from the Chief Counsel's National Office to requests for guidance from IRS field personnel. Beginning in 2002, the IRS "no longer refer[s] to the written legal advice prepared by the Associate offices for the Field as FSAs" though "Associate offices continue to provide written legal advice". See Chief Counsel Notice CC-2004-012, Q. 10 for more information.
See below for how to find Field Service Advice in the Finding Chief Counsel Advice tab.
Generic Legal Advice (GLA) are used by the National Office to provide legal analysis for a generic set of facts and address the "increased need for rapid, widely applicable, written advice". Furthermore, "[t]he GLA should only be used to provide guidance to the IRS". See Chief Counsel Notice CC-2009-002 for more information.
See below for how to find Generic Legal Advice in the Finding Chief Counsel Advice tab.
Service Center Advice (SCA) are legal advisories provided by the Chief Counsel's National Office to an IRS Service Center. They address the Service Center's tax administration responsibilities. See Chief Counsel Notice N(35)000-174 for more information about procedures for processing and disseminating SCA.
See below for how to find Service Center Advice in the Finding Chief Counsel Advice tab.
IRS Written Determinations Internal Revenue Service
Coverage begins with 1999.
Legal Advice Issued by Associate Chief Counsel Internal Revenue Service
Coverage begins with September 2006.
IRS Chief Counsel Advice
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Chief Counsel Advice. IRS Chief Counsel Advice is written advice or instruction that conveys legal interpretations or positions of the Service or the Office of Chief Counsel concerning existing or former revenue provisions. Chief Counsel Advice is written by any national office component of the Office of Chief Counsel to Chief Counsel field offices or Service field offices. Coverage begins with November 1998.
IRS Field Service Advice Memorandums (Archive)
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Field Service Advice Memorandums (Archive). IRS Field Service Memorandums provide non-binding case-specific written advice issued by the National Office of Chief Counsel to field personnel of either the Internal Revenue Service or the Office of Chief Counsel to help them develop an issue or determine litigation hazards for both substantive and procedural matters. Coverage from 1992 through 2003; selected documents back to July 1983. Beginning in 2004, the IRS Office of Chief Counsel no longer authors Field Service Advice Memorandums.
IRS Generic Legal Advice Memoranda
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Generic Legal Advice Memoranda. IRS Generic Legal Advice Memoranda are legal advice, signed by executives in the National Office of the Office of the Chief Counsel. They are issued to IRS national program executives and managers to assist Service personnel in administrating their programs by providing authoritative legal opinions on certain subjects. Coverage begins with June 2006.
IRS Non-Docketed Service Advice Reviews
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Non-Docketed Service Advice Reviews. IRS Non-Docketed Service Advice Reviews are written advice or instruction that conveys legal interpretations of the IRS Office of Chief Counsel regarding specific taxpayer situations. This advice is distributed to Chief Counsel field offices or Service field offices. Coverage begins with March 2003.
IRS Non-Taxpayer Specifics in Formal CCA
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Non-Taxpayer Specifics in Formal CCA. Contains non-taxpayer specific Chief Counsel advice written without respect to any specific taxpayer or group of specific taxpayers, but rather, addresses a general issue. Coverage begins with March 2004.
IRS Service Center Advice
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Service Center Advice. IRS Service Center Advice contains legal advice provided by the Office of Chief Counsel to IRS service centers and related IRS functions with respect to their tax administration responsibilities. This advice is distributed and published to provide consistent legal advice to all affected IRS functions and Counsel offices on matters raised by the various functions. Coverage from September 1997 through December 2005.
IRS Chief Counsel Advisories and Notices
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Chief Counsel Advisories and Notices. IRS Chief Counsel Advice are written advice documents issued to Chief Counsel field offices or IRS field offices, in response to requests for opinions and rulings by IRS field or service staff employees, or regional or district employees of the Office of Chief Counsel. These written determinations convey legal interpretations of revenue provisions; IRS or chief counsel positions or policy concerning revenue provisions; legal interpretation of a state, federal, or foreign law that relates to the assessment or collection of liabilities under a revenue provision. Coverage begins with 1999.
IRS Field Service Advice
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Field Service Advice. Contains legal memoranda prepared by the Office of Chief Counsel for IRS field attorneys, revenue agents, and appeals officers in response to requests for advice, guidance, and analysis on difficult or significant tax issues involving specific taxpayers. Coverage from 1992 through February 27, 2004, with one document dated May 11, 2013. Irregular coverage from 1976 through 1991. The Service now issues advice to the field as Chief Counsel Advice.
IRS Non Docketed Service Advice Review
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Non Docketed Service Advice Review. Contains documents providing IRS internal guidance in specific taxpayer situations. This written advice or instructions is prepared by the Office of Chief Counsel and issued to field or service center employees of the IRS or Office of Chief Counsel. Coverage begins January 1981. Older NSARs, which are dated prior to 1981, are being added as they are issued by the IRS.
IRS Service Center Advice
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Service Center Advice. Contains memoranda written by the Office of the Chief Counsel in response to requests for information by Internal Revenue Service service centers regarding interpretation of revenue provisions; IRS or chief counsel positions or policy concerning revenue provisions; or legal interpretation of a state, federal, or foreign law that relates to the assessment or collection of liabilities under a revenue provision. Coverage from 1999 through 2006.
Chief Counsel Advice Memoranda
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Guidance & Interpretation > Memoranda > Chief Counsel Advice Memoranda. IRS Chief Counsel Advice Memoranda are legal advice, signed by executives in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers. They are issued to assist Service personnel in administering their programs by providing authoritative legal opinions on certain matters, such as industry-wide issues. Coverage begins with 1999.
Field Attorney Advice
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Guidance & Interpretation > Memoranda > Field Attorney Advice. Legal advice released by Field attorneys in the Office of Chief Counsel. Coverage begins with 2003.
Field Service Advice Memoranda
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Guidance & Interpretation > Memoranda > Field Service Advice Memoranda. Field Service Advice Memoranda are taxpayer-specific rulings furnished by the IRS National Office in response to requests made by taxpayers and/or Service officials. Coverage begins with 1998.
Legal Advice Issued by Associate Chief Counsel (AMs)
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Guidance & Interpretation > Memoranda > Legal Advice Issued by Associate Chief Counsel (AMs). Legal advice providing legal opinions on various subjects signed by executives in the National Office of the Office of Chief Counsel and issued to the IRS personnel. Coverage begins with 2006.
Program Manager Technical Advice
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Guidance & Interpretation > Directives & Advice > Program Manager Technical Advice. Legal advice signed by attorneys in the National Office of the Office of Chief Counsel to aid in administering programs providing authoritative legal opinions on various matters. Coverage begins with June 2000.
Service Center Advice Memoranda
Available on the library's Bloomberg Law computers. From All Legal Content Search, select U.S. Regulatory & Administrative > U.S. Government Departments & Agencies > Internal Revenue Service > Guidance & Interpretation > Memoranda > Service Center Advice Memoranda. Service Center Advice Memoranda are documents prepared by field attorneys in the Office of Chief Counsel that are reviewed by an Associate Office, and subsequently issued to field or service center campus employees of the Internal Revenue Service. Coverage begins with 1997.
Chief Counsel Advice Memorandum
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > Chief Counsel Advice Memorandum. Chief Counsel Advice is written advice or instruction prepared and issued by the Office of Chief Counsel to field employees of the IRS or Office of Chief Counsel. The advice conveys legal interpretations or positions of the IRS or Office of Chief Counsel concerning existing or former revenue provisions. Chief Counsel Advice includes field service advice, technical assistance to the field, litigation guideline memoranda, tax litigation bulletins, general litigation bulletins, and criminal tax bulletins. Chief Counsel Advice is redacted prior to the public release. Coverage begins with 1994.
Field Service Advice Memorandum
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > Field Service Advice Memorandum. Field Service Advice Memorandum are issued by the Office of Chief Counsel in response to requests from field personnel of the IRS or the Office of Chief Counsel. The advice is a request for legal guidance with respect to the situation of a specific taxpayer. Coverage from 1986 through 2005. Select undated FSAs also available.
IRS - Service Center Advice Memorandum
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > IRS - Service Center Advice Memorandum. Coverage from 1997 through 2007.