Sandra Day O'Connor College of Law

Law Library

Tax - IRS Definitions

Actions on Decisions
—It is the policy of the Internal Revenue Service to announce at an early date whether it will follow the holdings in certain cases. An Action on Decision is the document making such an announcement. It is not intended to serve as public guidance and may not be cited as precedent.

Acquiescence—The recommendation in every Action on Decision will be summarized as acquiescence, acquiescence in result only, or nonacquiescence. Both "acquiescence" and "acquiescence in result only" mean that the Service accepts the holding of the court in a case and that the Service will follow it in disposing of cases with the same controlling facts. However, "acquiescence" indicates neither approval nor disapproval of the reasons assigned by the court for its conclusions; whereas, "acquiescence in result only" indicates disagreement or concern with some or all of those reasons.

Cumulative Bulletin—Hardbound compilation of the Internal Revenue Bulletins. Published every 6 months. 1919 to date.

Chief Counsel Advice—Written advice or instruction, under whatever name or designation, prepared by any national office component of the Office of Chief Counsel (OCC) which is issued to field or service center employees of the Service or regional or district employees of the Office of Chief Counsel and conveys any legal interpretation of a revenue provision, any IRS or OCC position or policy concerning a revenue provision or any legal interpretation of state, foreign or other federal law relating to the assessment or collection of any liability under a revenue provision.

Chief Counsel Notices—used by IRS to notify personnel of policies, procedures, instructions, and delegations of authority. They do not constitute authority for avoiding the substantial understatement penalty.

Delegation Order—publication issued by the IRS where the Commissioner of Internal Revenue delegates a portion of his statutory authority. These appear in the weekly Internal Revenue Bulletin.

IRS Exemption Rulings—released by the Internal Revenue Service's Exempt Organizations Technical Division, and issued under procedures announced in Notice 92-28, 1992-25 I.R.B. 5, 1992-1 C.B. 515. A ruling is a form letter that recognizes tax exemption under the Internal Revenue Code.

Field Service Advice Memoranda—provide non-binding case-specific written advice issued by the National Office of Chief Counsel to field personnel of either the Internal Revenue Service or the Office of Chief Counsel to help them develop an issue or determine litigation hazards for both substantive and procedural matters.

General Counsel Memoranda—documents issued by the General Counsel's office to IRS staff that indicate the reasoning and authority used in revenue rulings, private letter rulings, and technical advice memoranda. IRS personnel use them in formulating positions.

Information Letters—prepared by the national office of the Internal Revenue Service in response to requests for general information by taxpayers and members of Congress. Information letters provide general statements of well-defined law without applying them to a specific set of facts. They are advisory only and have no binding effect on the IRS.

Internal Revenue Bulletin—weekly IRS publication that contains the text of almost every primary non-judicial tax authority including: revenue rulings and procedures, regulations, Supreme Court tax decisions, treaties, tax legislation and reports, and acquiescences and nonacquiescences.

Internal Revenue Manual—IRS operating policies and procedures.

IRS Positions—a CCH publication that includes letter rulings, TAM's, Field Service Advice, Litigation Guideline memos, Service Center Advice memos, and other Chief Counsel Advice.

Litigation Bulletins—issued by the Chief Counsel's office, these documents provide information to IRS employees about litigation in a variety of areas including collection, bankruptcy, summonses (CBS), criminal tax (CTB), disclosure (DLB) and tax litigation (TLB).

Litigation Guideline Memoranda—Internal memoranda prepared to provide information and instruction on litigating procedures and methods, as well as standards and criteria on issues and matters of significant interest to litigating attorneys in the Office of Chief Counsel, including memoranda covering international litigation, disclosure litigation, criminal tax, general litigation, and tax litigation.

Letter Rulings—a general term that includes Private Letter Rulings, Determination letters and Technical Advice Memoranda issued by the IRS. See Private Letter Ruling for more information.

Nonacquiescence—The recommendation in every Action on Decision will be summarized as acquiescence, acquiescence in result only, or nonacquiescence. A nonacquiescence indicates that the IRS disagrees with the adverse decision in a case and will follow the decision only for the specific taxpayer whose case resulted in the adverse ruling.

Private Letter Rulings—written determinations issued by the National Office of the Internal Revenue Service that interpret and apply tax law to a taxpayer's specific set of facts. PLRs deal with pre-return filing transactions and are issued directly to individual taxpayers at their request.

Revenue Procedures—published statements of IRS practices and procedures. Revenue Procedures are published in the Internal Revenue Bulletin and the Cumulative Bulletin.

Revenue Rulings—Written determinations released by the IRS that interpret the tax laws as applied to specific factual situations. Revenue Rulings are selected for publication in the Internal Revenue Bulletin because of their potential interest to the general public.

Service Center Advice—The Office of Chief Counsel provides legal advice to IRS Service Centers and related IRS functions with respect to their tax administration responsibilities. This advice is distributed and published to provide consistent legal advice to all affected IRS functions and Counsel offices on matters raised by the various functions.

Technical Advice Memorandum—are issued by the national office in response to IRS requests arising out of tax return examinations. Unlike letter rulings, which focus on proposed transactions, TAMS cover completed transactions. In contrast to field service advice, TAMS involve both the taxpayer and the IRS, but both parties must agree on the underlying facts.

Treasury Decisions—Final and proposed regulations are issued as Treasury Decisions. Because the text of the regulation is added to the C.F.R., the most important information in the T.D. is the preamble.

Treasury Department Orders—documents issued by the Treasury Department as it exercises its control over the administrative organization of the IRS. These orders are selected for publication in the Internal Revenue Bulletin.

Treasury Regulations—the official interpretation of the Internal Revenue Code by the IRS and the Treasury Department used to enforce internal revenue laws. There are proposed, temporary and final regulations.

Technical Memorandum—Memoranda prepared by the Internal Revenue Service in support of proposed Treasury decisions that provide background information and explain the reasoning underlying the proposals.


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