"General Counsel Memorandums (GCM) are legal memorandums from the Office of Chief Counsel prepared in connection with the review of certain proposed rulings (Rev. Ruls., PLRs, TCMs). They contain legal analyses of substantive issues and can be helpful in understanding the reasoning behind a particular ruling and the Service’s response to similar issues in the future." Internal Revenue Manual 4.10.7.2.11 (Jan. 1, 2006).
See below for how to find memorandums from the Office of Chief Counsel.
Litigation Guideline Memorandums (LGM) were a form of legal advice prepared by attorneys in the National Office of the Office of Chief Counsel that "provide[d] information and instruction relating to litigating procedures and methods, and standards and criteria on issues and matters of significant interest to litigating attorneys in the Office of Chief Counsel".
LGMs were discontinued in 1999: "The Office of Chief Counsel issued its last LGM in 1999. The Office has since discontinued preparing Litigation Guideline Memorandums and instead issues legal advice and litigation guidance through a number of other written work products, including Chief Counsel Notices, formal and informal Chief Counsel advice memorandums, generic legal advice memorandums, program manager technical advice, and updates to the Chief Counsel Directives Manual (CCDM). Because LGMs no longer serve their original purpose of providing confidential legal advice and litigation guidance to Chief Counsel attorneys, and have been superseded by other Chief Counsel work products, they will no longer be prepared and issued by the Office of Chief Counsel. To the extent that existing LGMs have not been formally obsoleted or withdrawn, they may now be considered obsolete." See Chief Counsel Notice CC-2017-001 (Nov. 2, 2016) for more information.
See below for how to find memorandums from the Office of Chief Counsel.
"Technical Advice Memorandums (TAM) are requested by IRS area offices after a return has been filed, often in conjunction with an ongoing examination. TAMs are binding on the Service in relation to the taxpayer who is the subject of the ruling." Internal Revenue Manual 4.10.7.2.10 (2) (Jan. 1, 2006).
See below for how to find memorandums from the Office of Chief Counsel.
"Technical Memorandums (TM) function as transmittal documents for Treasury Decisions or Notices of Proposed Rule Making (NPRMs). They generally summarize or explain proposed or adopted regulations, provide background information, state the issues involved, and identify any controversial legal or policy questions. Technical Memorandums are helpful in tracing the history and rationale behind a regulation or regulation proposal." Internal Revenue Manual 4.10.7.2.12 (Jan. 1, 2006).
See below for how to find memorandums from the Office of Chief Counsel.
IRS Written Determinations Internal Revenue Service
Includes all types of Written Determinations, including Chief Counsel Advice, Technical Advice Memoranda, and Written Determinations. Coverage begins with 1999.
Select Technical Memoranda may also be available on free internet resources, like Legalbitstream.com.
IRS Private Rulings and Advice TaxNotes
Filter by 'Legal Memorandums'.
IRS General Counsel Memoranda (Archive)
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS General Counsel Memoranda (Archive). IRS General Counsel Memoranda are documents issued by the Internal Revenue Service General Counsel in response to legal questions asked by the IRS staff. Coverage from March 1967 through November 2002; selected GCMs, October 1958 through March 1967.
IRS Litigation Guideline Memorandums (Archive)
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Litigation Guideline Memorandums (Archive). Litigation Guideline Memorandums provide information and instruction on litigating procedures and methods, and standards and criteria on issues and matters of significant interest to litigating attorneys in the Office of Chief Counsel. Coverage from January 1986 through March 1999.
IRS Private Letter Rulings and Technical Advice Memoranda
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Private Letter Rulings and Technical Advice Memoranda. IRS Private Letter Rulings and Technical Advice Memoranda are written determinations issued by the National Office of the Internal Revenue Service that interpret and apply tax law to a taxpayer's specific set of facts. Technical Advice Memoranda deal with refund claims and examination issues after a return has been filed; the request for a TAM is made by a district IRS office, although such a request often follows a taxpayer's suggestion that technical advice be sought. Coverage begins with 1954.
IRS Technical Memoranda (Archive)
Available on the library's Lexis computers. From the Practice Area tab, select Tax Law > All Tax Law Administrative Materials > IRS Technical Memoranda (Archive). IRS Technical Memoranda are documents issued by the Internal Revenue Service which examine final regulations. Coverage from July 1967 through June 1993.
IRS Chief Counsel Attorney Memoranda
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 Attorney Memoranda. Attorney Memoranda are written by the Office of the Chief Counsel in response to requests for opinions by Internal Revenue Service (IRS) field or service staff employees, or regional or district employees of the Office of Chief Counsel. Coverage begins with 2006, when these memoranda were first issued.
IRS General Counsel Memoranda
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > General Counsel Memoranda. Contains memoranda prepared by the Internal Revenue Service Office of Chief Counsel in support of revenue rulings, private letter rulings, and technical advice memoranda issued by the IRS. Coverage from 1962 through 2002. After 2002, guidance previously issued as a Chief Counsel Memoranda are now issued as Chief Counsel Advisories.
IRS Litigation Guideline Memoranda
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Litigation Guideline Memoranda. Contains internal memoranda prepared to provide information and instruction on litigating procedures and methods, as well as standards and criteria on issues and matters of significant interest to litigating attorneys in the Office of Chief Counsel, including memoranda covering international litigation, disclosure litigation, criminal tax, general litigation, and tax litigation. Coverage from 1988 through 2000 (with one document being issued in 2001). Limited coverage from 1976 through 1987. Such guidance documents are now issued as Chief Counsel Notices.
IRS Technical Advice Memoranda
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Technical Advice Memoranda. Contains written determinations issued by the Internal Revenue Service in response to a district director's request for advice or guidance relative to a specific fact situation arising out of a tax return audit. Coverage begins with 1954 (excepting illegible documents).
IRS Technical Memoranda
Available on the library's Westlaw computers. From the Practice areas tab, select Tax > Administrative Decisions & Guidance > All Internal Revenue Service (IRS) Materials > Technical Memoranda. Contains memoranda prepared by the Internal Revenue Service in support of proposed Treasury decisions that provide background information and explain the reasoning underlying the proposals. Coverage begins with 1967 through 1993.
General Counsel 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 > General Counsel Memoranda. General Counsel Memoranda are documents prepared by the Office of Chief Counsel that the Office has determined should be made available to the public, due to the nature of their subject matter. It is important to note that such items cannot be used or cited as precedent. Coverage begins with 1962.
Technical 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 > Technical Advice Memoranda. Technical Advice Memoranda ("TAMs") are taxpayer-specific rulings furnished by the IRS National Office in response to requests made by taxpayers and/or Service officials. Coverage begins with 1979.
General Counsel Memorandum
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > General Counsel Memorandum. General Counsel Memorandum are legal analyses prepared by the Office of Chief Counsel and can not be used or cited as precedent. They set forth the issue being examined, a brief factual summary, an analysis of the issue, and the recommendation and opinion of the Office of Chief Counsel. Coverage from 1960 through 2002.
IRS Letter Rulings and TAMS (Current)
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > IRS Letter Rulings and TAMS (Current). Current year only.
Litigation Guideline Memorandum
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > Litigation Guideline Memorandum. Litigation Guideline Memoranda is written guidance from the IRS to its attorneys in the field with instructions on how to litigate a particular issue. Coverage from 1976 through 1999.
Miscellaneous IRS Memorandum
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > Miscellaneous IRS Memorandum. Miscellaneous IRS Memorandum includes IRS advice memorandum from the Office of the Chief Counsel to its area counsel providing guidance on various issues. Coverage begins with 2007.
Technical Memoranda
Available on the library's VitalLaw computer. From Practice Areas, select Tax - Federal > Primary Sources > IRS Administrative Rulings & Positions > See All > Technical Memoranda. Coverage from 1970 through 1989.
IRS Letter Rulings CCH
Library has 1977-1993, 2004-2009. Index coverage, 1977-1999. Indexed by Subject and Code Section. See Transfer Binders. For rulings from 1977-1993, see Microforms.
IRS Positions Reporter CCH
For 1982-2013, see Transfer Binders. Also available on the library's VitalLaw computer as IRS Audit Positions.
The Standard Federal Tax Reporter includes select memoranda from the Office of Chief Counsel, including General Counsel Memoranda and Technical Advice Memoranda.
Jenkins has access to the Standard Federal Tax Reporter on the library's VitalLaw computer beginning with 1986. Pre-1986 coverage is available on the member database HeinOnline. Select coverage is also available in print. See the Standard Federal Tax Reporter page of this guide for more information.