CN 2 - ChrisNotes 2 7 ADMINISTRATIVE AUTHORITY(continued...

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Unformatted text preview: ChrisNotes 2 - 7 ADMINISTRATIVE AUTHORITY (continued). Revenue Ruling . Revenue Rulings are the official pronouncements of the National Office of the IRS. Like Regulations, they interpret the tax law. However, they address narrower issues and are persuasive authority, not binding authority. Revenue Procedures. Revenue Procedures are issued in the same manner as Revenue Rulings, but deal with the internal management practices and procedures of the IRS. Determination letters. Determination letters are issued at the request of taxpayers and provide guidance on the application of the tax law on completed transactions. Unlike letter rulings, determination letters are issued by the District Director rather than the National Office of the IRS. Technical Advice Memoranda gTAM’s). TAM’s are issued by the National Office of the IRS to one of the four regional offices, or 33 district offices, in order to address questions by IRS personnel concerning tax treatment for completed transactions. Private Letter Rulings. Individual letter rulings are issued by the National Ofiice of the IRS upon a taxpayer’s request, for a fee, and describe how the IRS will treat a proposed transaction for tax purposes. 73 more easily distinguish among “Determination Letters," “TAMs,” and “Private Letter Rulings,” note the requests clarification, from whom, and whether it concerns a completed or a proposed transaction: - Determination Letters: Requested by taxpaver for the IRS District Office to address a completed transaction. - TAMs: Requested by LIE for its National Office to address a completed transaction. - Private Letter Ruling: Requested by taxpayer for the IRS National Office to address a proposed transaction. JUDICIAL AUTHORITY. Doctrine of Stare Decisis. Under this doctrine, the courts must stand on their own decisions. In other word, a court’s decision is binding to that same court’s future decisions regarding the same controlling set of facts. Chapter 2 h. ‘ p tummy) _ ._”.Ls . n Anni-u” 9 MNN’J 2: mdeuo ...
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