What is a technical advice memorandum? Who may request it? What kinds of issues are addressed therein? Does the IRS include technical advice memoranda in any official publication?
Answer to relevant QuestionsDiscuss the precedential value of private letter rulings, determination letters, and technical advice memoranda. What role do these items play in conducting tax research? Explain each of the elements of this citation: Rev. Proc. 2013-14, 2013-3 I. R. B. 283. Must the IRS acquiesce or nonacquiesce to every issue in a court decision? Briefly describe the subject of each of the following letter rulings. State the type [private letter ruling (PLR), field service advice (FSA), service center advice (SCA), etc.] of each letter ruling. a. 200034026 b. ...Your client, Jack Benny, and his wife were divorced last year. Jack had been employed by the city of Rancho Cucamonga for 30 years. Jack was a participant in a defined-benefit pension plan. He had been eligible to start ...
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