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Federal Tax Research  

This guide provides information on federal tax law and identifies pertinent print and online resources available through the NYU Law Library.
Last Updated: Nov 13, 2017 URL: http://nyulaw.libguides.com/content.php?pid=271175 Print Guide RSS Updates

Chief Counsel Advice & Other Materials Print Page
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Chief Counsel Advice

"Chief counsel advice is an umbrella term that encompasses any written advice prepared by any National Office component of the Office of Chief Counsel or division counsel headquartered in Washington and issued to IRS counsel or field office employees that conveys a legal interpretation or IRS counsel position or policy regarding a revenue provision." (IRS Guidance 1980-2003: An Ever-Changing Landscape Notes, Tax Notes)

"Chief Counsel Advice (CCA) materials 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." (IRS Website)

"IRC § 6110(i)(1)(A) defines CCA as written advice or instruction, under whatever name or designation, prepared by any National Office component of the Office of Chief Counsel that A. Is issued to Field or Service Center employees of the Service or Field employees of the Office of Chief Counsel, and B. Conveys any legal interpretation of a revenue provision, any Service or Office of Chief Counsel position or policy concerning a revenue provision, or any legal interpretation of State law, foreign law, or other Federal law relating to the assessment or collection of any liability under a revenue provision. CCA includes both taxpayer specific and nontaxpayer specific advice." (Definition of Chief Counsel Advice, IRM § 33.1.3.1.1)

      

    Abbreviation, Chief Counsel Advice

    Below is a pertinent abbreviation.

    • Chief Counsel Advice=CCA
        

      Sources for Chief Counsel Advice

      Below are links to select sources offering chief counsel advice. Consult other pages in this guide for other types of advice from IRS attorneys.

      • Chief Counsel Advice, RIA
        1994-. Under the "Table of Contents" tab, navigate: Federal Library→Federal Source Materials→IRS Rulings & Releases→Private Letter Rulings & TAMs, FSAs, SCAs, CCAs, GCMs, AODs & Other FOIA Documents→Chief Counsel Advice.
      • Chief Counsel Advice Memorandum, CCH
        1998-. "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. . . . 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." (CCH)
      • IRS E-Mail Chief Counsel Advice, Tax Analysts
        "Internal e-mails containing legal advice written by the Office of Chief Counsel and sent to IRS field personnel." Click on Research Tools→Federal Research Library→IRS Written Determinations (under "Browse Documents")→E-mail Chief Counsel Advice (from pull down bar)
      • IRS Legal Memos, Tax Analysts
        1990-. "Uniquely titled by Tax Analysts, ILMs are memorandums issued by the Chief Counsel's office in answer to district counsel queries and address a specific issue or situation confronting the district counsel." Click on Research Tools→Federal Research Library→IRS Written Determinations (under "Browse Documents")→Legal Memorandums (from pull down bar)
      • Non-precedential Rulings & Advice, IRS Website

      Other Sources of IRS Attorney-Authored Materials

      Below are links to other sources of advice issued by IRS attorneys to employees.

      • General Counsel Memorandum (Practice Areas) , CCH
        "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." (CCH)
      • IRS Chief Counsel Notices, Tax Analysts
        "Contains the full texts of nearly every Chief Counsel Notice issued since 1988. Chief Counsel Notices are temporary directives the IRS national office uses to disseminate policies, procedures, instructions, and/or delegations of authority to Chief Counsel employees." Click on Research Tools→Federal Research Library→IRS Written Determinations (under "Browse Documents")→Chief Counsel Notices (from pull down bar)
      • IRS Field Attorney Advice, Tax Analysts
        "Contains the full texts of every Field Attorney Advice issued. FAAs are legal advice prepared by field attorneys of the Office of Chief Counsel issued to field or service center employees." Click on Research Tools→Federal Research Library→IRS Written Determinations (under "Browse Documents")→Field Attorney Advice (from pull down bar)
      • IRS Generic Legal Advice, Tax Analysts
        2006-. "Generic Legal Advice 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." Click on Research Tools→Federal Research Library→IRS Written Determinations (under "Browse Documents")→Generic Legal Advice (from pull down bar)
      • IRS Litigation Guideline Memorandums, Tax Analysts
        " LGMs were guidance from the IRS National Office to the field instructing the field how to litigate a particular issue. LGMs were designed to ensure that the IRS's approach to litigating particular issues is uniform. The IRS first released LGMs in 1986 and released them on a random basis through 1999." Click on Research Tools→Federal Research Library→IRS Written Determinations (under "Browse Documents")→Litigation Guideline Memorandums (from pull down bar)
      • IRS Program Manager Technical Assistance, Tax Analysts
        "Program Manager Technical Assistance are internal memorandums containing legal advice written by the Office of Chief Counsel to national program managers." Click on Research Tools→Federal Research Library→IRS Written Determinations (under "Browse Documents")→Program Manager Technical Assistance (from pull down bar)
      • Legal Advice Issued by Field Attorneys, IRS Website
      • Legal Advice Issued to Program Managers, IRS Website
      • Program Manager Technical Advice, Bloomberg BNA
        1970-.
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