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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The technical advice memorandum states that the survey "clearly establishes that associate members are attracted by insurance coverage and not agricultural pursuits." This, despite the fact that associate memberships have been a part of the organization for nearly 50 years--before insurance was even made available.
In Technical Advice Memorandum (TAM) 200603027, the JRS concluded the scope of a LIFO election is "linked" to a taxpayer's LIFO pooling method; thus, the taxpayer's LIFO election must extend to all items that fall within the LIFO pools.
TEI understands that the IRS is considering issuing additional guidance on the treatment of CLAs, perhaps in the nature of a technical advice memorandum (TAM).
To its credit, the national office simply raised the issue of a swing-vote value in Technical Advice Memorandum 9436005, knowing that the facts of each case will determine if such a value exists.
Technical Advice Memorandum 200437030 discusses the question of administrable impracticality in an evaluation of how gift certificates should be treated.
TEI understands that the IRS may be considering issuing a technical advice memorandum or private letter ruling addressing the tax consequences that flow from cross-license agreements (CLAs).
However, a private letter ruling (PLR 8921101) and a technical advice memorandum (TAM 9435001) suggest this is the case, illustrating the importance of having a recordkeeper that can separately account for which shares the plan acquired before August 4, 1989.
In Technical Advice Memorandum (TAM) 200224004, the IRS held Federal Communications Commission (FCC) television licenses were like-kind to FCC radio licenses, by focusing on the underlying property's fundamental nature (i.e., a portion of the electromagnetic spectrum), rather than on asset use.
This determination can no longer be made by revenue agents, branch-level attorneys within the National Office (such as through a technical advice memorandum), or other subordinate IRS personnel.
The Internal Revenue Service has disallowed a company's deductions for the costs of using its aircraft to transport a company officer/ shareholder and spouse to and from vacation sites in the United States (technical advice memorandum (TAM) 9715001).
In Technical Advice Memorandum (TAM) 200609018, the IRS relied on traditional cost accounting principals to determine whether the costs of a taxpayer's engineering and procurement departments qualified as mixed service costs (MSC) that can be allocated between capitalizable activities and deductible activities under Regs.
Grassley (R-Iowa) said he would pursue legislative efforts to reverse Ilks technical advice memorandum 9640003 that was issued in October 1996.

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