Technical Advice Memoranda

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The IRS recently released this TAM on excess business holdings. It's based on an interesting set of facts.

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The Service has ruled in technical advice that an organization is properly classified as a supporting organization under section 509(a)(3). At issue was whether the organization was controlled directly or indirectly by one or more disqualified persons. The Service...
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The Service has ruled in technical advice that loans from a corporation that is a disqualified person with respect to a private foundation to another business entity, a portion of which is also owned by the private foundation, is not an indirect act of self-dealing...
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In technical advice, the Service has ruled that an individual's bequest to a sister who belongs to a religious order and took a vow of poverty does not qualify for an estate tax charitable deduction.
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The IRS has ruled in technical advice that although an organization is no longer a church, it will retain its tax-exempt status and be subject it to intermediate sanctions for automatic excess benefit transactions and political intervention.
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TAM 200435021

Full Text:

Release Date: 8/27/04
UIL: 4958.00-00
T:EO:B3

May 5, 2004

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CEO'S Spouse is Disqualified Person Under Section 4958
Full Text: UIL: 501.00-00, 4958.00-00

Date: June 21, 2002

INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Refer Reply To:

T:EO:B1...

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The Service has ruled in technical advice that no gift tax charitable deduction is allowed for transfers to a trust that is subject to four charities' withdrawal powers. Further ruled, each transfer is includable in the computation of adjusted taxable gifts to the...
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TAM 200243057
Full Text:

UIL: 9999.98-00

Date: July 2, 2002

Refer Reply To: T:EO:B4

INTERNAL REVENUE SERVICE

TE/GE TECHNICAL ADVICE...

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TAM 199925043

TAM 199925043

Full Text:

Index (UIL) No.: 2106.03-00
CASE MIS No.: TAM-117619-98

Date: March 8, 1999

Control Number: * * *

LEGEND:
Decedent = * * *
Date 1 = * * *
...

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Full Text:

Date: October 14, 1993

Control No.: TR-32-196-93

District Director * * *
Taxpayer's Name: * * *
Taxpayer's Address: * * *
Date of Death: * * *
Taxpayer's SSN: * * *
Date of conference...

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Full Text:

November 15, 1985

LEGEND:
Taxpayer's Name: * * *
Taxpayer's Address: * * *
Taxpayer I.D. No.: * * *
Date of Death: * * *
No conference held
Decedent = * * *
X Partnership = * * *
A...

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TAM 9223002
TAM 9223002 

Full Text:

Date: February 13, 1992

District Director: * * *
Taxpayer's Name: * * *
Taxpayer's Address: * * *
Taxpayer's Identification Number: * * *...

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In this Technical Advice Memorandum, the IRS held that a broadcasting company is not entitled to an income tax charitable deduction for contributing its zero basis film library to a public charity, in part because the film library is not a capital asset.
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IRS is barred by the 3-year statute of limitations from taking action against a private foundation and disqualified person for a self-dealing transaction.
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In Technical Advice Memorandum 200021056, the Service concluded that a tax-exempt organization's operation of a gift shop and tea room were unrelated to its exempt purpose and held that the resulting income constitutes unrelated business taxable income and further held...
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In TAM 200003005, the Service advised, in part, that a printing company did not meet the requirements for an increased charitable deduction under Section 170(e)(3) of the Code for donated inventory because the company could not demonstrate that the donated materials...
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Define: Technical Advice Memoranda

A technical advice memorandum, or TAM, is guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director in response to technical or procedural questions that develop during a proceeding. A request for a TAM generally stems from an examination of a taxpayer’s return, a consideration of a taxpayer’s claim for a refund or credit, or any other matter involving a specific taxpayer under the jurisdiction of the territory manager or the area director, appeals. TAMs are issued only on closed transactions and provide the interpretation of proper application of tax laws, tax treaties, regulations, revenue rulings or other precedents. The advice rendered represents a final determination of the position of the IRS, but only with respect to the specific issue in the specific case in which the advice is issued. Like PLRs, TAMs are not precedential for other taxpayers and are generally made public after all information has been removed that could identify the taxpayer whose circumstances triggered a specific memorandum.