Federal Tax Research: Technical Advice Memoranda

"A technical advice memorandum, or TAM, is guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director, appeals, in response to technical or procedural questions that develop during a proceeding. A request for a TAM generally stems from an examination of a taxpayer's return, a consideration of a taxpayer's claim for a refund or credit, or any other matter involving a specific taxpayer under the jurisdiction of the territory manager or the area director, appeals." (IRS Website)

"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." (Private Letter Rulings and Technical Advice Memorandums, IRM § 4.10.7.2.10)

TAMs are not published in the Internal Revenue Bulletin.

The following citation resources may be informative.

• Bluebook T 1.2, Federal Administrative & Executive Materials ("Technical Advice Memoranda: Cite by number and the date issued, if available. > I.R.S. Tech.Adv.Mem. 85-04-005 (Sept. 28, 1984) . . .")

• Bluebook R. 14, Administrative and Executive Materials

• IRM § 4.10.7.2.10.2, Citing PLRs and TAMs ("Letter rulings and technical advice memorandums are cited PLR or TAM, respectively, followed by a seven digit number. For example, PLR 8210019 or TAM 9643001. The first two digits indicate the year the ruling was published, for example, 1982 and 1996, respectively . . .")

• TaxCite, Pt. 1, C. 3c, Private Letter Rulings and Technical Advice Memoranda

Below are links to select sources offering technical advice memoranda.

Below is a pertinent abbreviation.

• Technical Advice Memorandum=Tech. Adv. Memo. or T.A.M. or TAM