Research guides

Federal Taxation

Chief Counsel Advice

Chief Counsel Advice, Field Service Advice, Generic Legal Advice, Non-Docketed Service Advice Review, and Service Center Advice are internal IRS documents that advise IRS personnel on legal matters at all stages of case development. More information on each type of Chief Counsel Advice is available below.

Chief Counsel Advice (CCA) are legal advisories written by the Chief Counsel's National Office to advise IRS personnel at all stages of case development. They convey legal interpretations or positions of the Office of Chief Counsel regarding existing or former revenue provisions. CCAs are not published in the Internal Revenue Bulletin.

Field Service Advice (FSA) are memoranda prepared by the Chief Counsel's National Office for IRS field attorneys, revenue agents, and appeals officers in response to requests for advice, guidance, and analysis on difficult or significant tax issues involving specific taxpayers. The IRS began to phase them out in 2002 and replace them with Chief Counsel Advice. For where to find Chief Counsel Advice, see the information below. FSAs were not published in the Internal Revenue Bulletin.

Generic Legal Advice (GLA) are used by the National Office to provide legal analysis for a generic set of facts or to suggest alternate legal theories and appropriate ways of developing the facts necessary for applying these theories. They are intended for IRS personnel, not the taxpayer. GLAs are not published in the Internal Revenue Bulletin.

Service Center Advice (SCA) are legal advisories provided by the Chief Counsel's National Office to an IRS Service Center. They address the Service Center's tax administration responsibilities. SCAs are not published in the Internal Revenue Bulletin.

The advice types listed in this tab are only a selection of the advice formats issued by the Office of Chief Counsel through the years. Some of the resources in the Treatises page of this guide may offer more information on the Office of Chief Counsel and Chief Counsel Advice.

Online

IRS Written Determinations Internal Revenue Service
Coverage begins in 1999.

Legal Advice Issued by Associate Chief Counsel Internal Revenue Service
Coverage begins in September 2006.

Onsite Lexis

IRS Chief Counsel Advice
Available on the library's Lexis computers. From the Practice Area or Industry tab, select Tax Law > All Tax Law Administrative Materials > IRS Chief Counsel Advice. Coverage begins in November 1998.

IRS Field Service Advice Memorandums (Archive)
Available on the library's Lexis computers. From the Practice Area or Industry tab, select Tax Law > All Tax Law Administrative Materials > IRS Field Service Advice Memorandums (Archive). From 1992 through 2003; selected documents back to July 1983. Beginning in 2004, the IRS Office of Chief Counsel no longer authors Field Service Advice Memorandums.

IRS Generic Legal Advice Memoranda
Available on the library's Lexis computers. From the Practice Area or Industry tab, select Tax Law > All Tax Law Administrative Materials > IRS Generic Legal Advice Memoranda. Coverage begins in June 2006.

IRS Non-Docketed Service Advice Reviews
Available on the library's Lexis computers. From the Practice Area or Industry tab, select Tax Law > All Tax Law Administrative Materials >IRS Non-Docketed Service Advice Reviews. From March 2003 through current.

IRS Service Center Advice
Available on the library's Lexis computers. From the Practice Area or Industry tab, select Tax Law > All Tax Law Administrative Materials > IRS Service Center Advice. Coverage from September 1997 through December 2005.

Onsite Westlaw

IRS Chief Counsel Advisories and Notices
Available on the library's Westlaw computers. From the All Content tab, select Administrative Decisions & Guidance > Internal Revenue Service IRS (listed under All Federal Administrative Decisions & Guidance) > Chief Counsel Advisories and Notices. Coverage for Chief Counsel Advisories begins with 1999 and Chief Counsel Notices coverage begins in 1995.

IRS Field Service Advice
Available on the library's Westlaw computers. From the All Content tab, select Administrative Decisions & Guidance > Internal Revenue Service IRS (listed under All Federal Administrative Decisions & Guidance) > Field Service Advice. Full coverage, 1992 - February 27, 2004; selective coverage, 1976-1991. The Service now issues advice to the field as Chief Counsel Advice.

IRS Non Docketed Service Advice Review
Available on the library's Westlaw computers. From the All Content tab, select Administrative Decisions & Guidance > Internal Revenue Service IRS (listed under All Federal Administrative Decisions & Guidance) > Non Docketed Service Advice Review. Coverage begins with 1981. Older NSARs are being added as they are issued by the IRS.

IRS Service Center Advice
Available on the library's Westlaw computers. From the All Content tab, select Administrative Decisions & Guidance > Internal Revenue Service IRS (listed under All Federal Administrative Decisions & Guidance) > Service Center Advice. Coverage from 1999 - 2006.