IRS Technical Advice Requests
A technical advice memorandum, or TAM, is guidance furnished by the IRS Office of Chief Counsel upon the request of a taxpayer or an IRS area director or Appeals Officer, in response to technical or procedural questions that develop during an audit or administrative appeal. A request for a TAM can arise from an examination of a business’ or an individual’s tax return, or from consideration of a claim for a refund or credit. TAMs are often sought in situations where there is little guidance on a specific matter, or it appears the IRS is treating one taxpayer differently from another in substantially the same situation.
Technical Advice Memoranda are only issued on completed transactions and provide the Office of Chief Counsel’s interpretation of the proper application of tax laws, tax treaties, regulations, revenue rulings or other precedent to that transaction. The advice rendered represents a final determination of the position of the IRS, but only with respect to the specific issue in the specific case in which the advice is rendered.
At Thorn Law Group, we have successfully represented businesses in Technical Advice Memorandum requests. Contact Thorn Law Group’s Kevin E. Thorn today at 202 349-4033 to learn more about IRS Technical Advice Memoranda and whether seeking a TAM may benefit you.
