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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Relying primarily on two 1991 federal appellate court decisions, which held that membership dues paid to a union were unrelated business income because membership yielded no privileges other than access to the union's health insurance plan, the IRS ruled in Technical Advice Memorandum 9416002 that the associate members of the agricultural organization are not bona fide members but join the organization primarily to gain access to the organization's auto, life, and health insurance plans.
Based upon our interpretation of a recent IRS technical advice memorandum, each participant will therefore receive an additional earnings allocation of approximately $38 per share, in addition to the $47 tender price per share.
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.
In a recent technical advice memorandum (TAM 200602034), the Internal Revenue Service provided restrictive guidance on this topic.
Presumably this means it will reject requests to extend the time within which a taxpayer may file a claim (see technical advice memorandum 9138002).
One dramatic example of this type of abuse is seen in a recent Technical Advice Memorandum (TAM 9719006) issued by the IRS National Office on March 1, 1997.
MacDonald, has reacted to the recent IRS technical advice memorandum (TAM) on equity split-dollar life insurance.
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 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.
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.
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).

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