technical advice memorandum

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technical advice memorandum (TAM)

A written interpretation of tax law as it relates to a specific problem posed by a specific taxpayer.The question must regard a closed transaction—a dispute over the treatment of something done in the past,not a request for advice on how to proceed in the future.Only an IRS district director or the chief of a local Appeals Office may request a TAM, which is then written by the National Office.TAMs are binding on the IRS for only the transaction at hand. Other taxpayers who use the TAM as guidance for their own actions do so at their own risk,because the IRS may take the opposite position the next time. Contrast with a private letter ruling, which has the same effect but the guidance comes from the local office and the advice relates to a future transaction. Contrast also with a revenue ruling, which is often issued in response to a particular taxpayer problem but which may be used by all other taxpayers as authority for their actions.
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TAM: One of the biggest travel agencies in Brazil, TAM Viagens offers more than 600 tourist destinations.
Egg production, egg weight, albumin weight, yolk weight, and shell thickness of different TAM treated groups are presented in Table 1.
The talks are being led by Andre Esteves, the Brazilian billionaire head of investment bank BTG Pactual, who is also a board member of TAM, Exame said.
IBM's solution is expected to help solve challenges associated with the check-in system, software used by TAM employees to sell airline tickets and reserve seats on flights and server reliability.
In remarks before the ABA Section of Taxation on May 5, 2006, you acknowledged any effective TAM process "must include among its characteristics an honest and forthright effort by the Service and Counsel to reevaluate any positions formulated in either the Case Specific or Generic Legal Advice in light of specific arguments advanced by the taxpayers and their representatives during the TAM process.
Moreover, the IRS might use the position stated in TAM 200603027 to require the taxpayer to link the new LIFO pools and the items accounted for under the LIFO method.
TAM 98D-102 and TAM 98D-99ne were advanced through performance tests from 1999 to 2001 at two to eight locations across south and central Texas.
Tam, David and many other immigrants have worked hard for their families and for all of us.
MIA Farrow has thrown herself into caring tirelessly for her remaining 13 children - nine of them adopted - after blind daughter Tam died in her arms.
HOLLYWOOD star Mia Farrow is mourning the loss of her daughter Tam, who has died of heart failure.
The decision brings into greater focus the ongoing constitutional challenges to qui tam suits under the False Claims Act.
In TAM 9721002, a buyer, which had purchased a target's stock in a transaction it had elected to treat as an asset acquisition, terminated employees whose severance rights had been established in preacquisition plans.