Question: Discuss the precedential value of private letter rulings determination letters
Discuss the precedential value of private letter rulings, determination letters, and technical advice memoranda. What role do these items play in conducting tax research?
Answer to relevant QuestionsWhich IRS documents are open to public inspection under I. R. C. § 6110? Explain each of the elements of this citation: Rev. Proc. 2000-41, 2000-2 C. B. 317. What is the purpose of each of the following? a. Technical memorandum (TM) b. General counsel memorandum (GCM) c. Action on decision (AOD) Briefly describe the subject of each of the following letter rulings. a. 200940016 b. 201009012 c. 201136009 d. 201247022 Many years ago your client Lucy Hapless (currently single and age 48) started working with Sham Credit Swap (SCS) Inc., where she participated in the company’s 401(k) plan. Five years ago, she took out a home loan from her ...
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