Research guides

Federal Taxation

Chief Counsel Memoranda

General Counsel Memoranda, Litigation Guideline Memoranda, Technical Advice Memoranda, and Technical Memoranda are internal IRS memoranda that frequently discuss technical and procedural matters. More information on each type of memorandum is available below.

General Counsel Memoranda (GCM) are prepared by Chief Counsel attorneys and are intended primarily for IRS internal use. They are similar to standard attorney opinions and indicate the reasoning behind revenue rulings, private letter rulings, and technical advice memoranda. Generally, GCMs were replaced by Chief Counsel Advice after 2002. For where to find Chief Counsel Advice, see the Chief Counsel Advice page of this guide. They were not published in the Internal Revenue Bulletin.

Litigation Guideline Memoranda (LGM) were written by the National Office as guidance to Field Offices on how to approach litigation. They discuss tactical considerations and strategy on various fact patterns. LGMs were issued between 1986 and 1999. They are now issued as Chief Counsel Notices. For where to find Chief Counsel Notices, see the Chief Counsel Notices page of this guide. LGMs were not published in the Internal Revenue Bulletin.

Technical Advice Memoranda (TAM) are a type of Written Determination. They are issued by the National Office of Chief Counsel in response to an IRS field office's request. They are responses to technical or procedural questions. They are not published in the Internal Revenue Bulletin.

Technical Memoranda (TM) are a type of Chief Counsel Advice. They provide background information on regulations. Usually they are from the Chief Counsel's Office to the Treasury. The IRS stopped issuing TMs in November 1993.

Online

IRS Written Determinations Internal Revenue Service
Includes all types of Written Determinations, including Chief Counsel Advice, Technical Advice Memoranda, and Written Determinations. 1999 - present.

Research Tip

Select Technical Memoranda may also be available on free internet resources, like Legalbitstream.com.

Onsite Lexis

IRS General Counsel Memoranda (Archive)
Available on the library's Lexis computers. From the Practice Area or Industry tab, select Tax Law > All Tax Law Administrative Materials > IRS General Counsel Memoranda (Archive). Coverage from March 1967 - November 2002; selected GCMs, October 1958 - March 1967.

IRS Litigation Guideline 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 Litigation Guideline Memorandums (Archive). Coverage from January 1986 through March 1999.

IRS Private Letter Rulings and Technical 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 Private Letter Rulings and Technical Advice Memoranda. Coverage begins in 1954.

IRS Technical Memoranda (Archive)
Available on the library's Lexis computers. From the Practice Area or Industry tab, select Tax Law > All Tax Law Administrative Materials > IRS Technical Memoranda (Archive). Coverage from July 1967 through June 2002.

Onsite Westlaw

IRS General Counsel Memoranda
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) > General Counsel Memoranda. Coverage from 1962-2002.

IRS Litigation Guidance Memoranda
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) > Litigation Guideline Memoranda. Coverage from 1988-2000. Select memoranda from 1976-1987.

IRS Technical Advice Memoranda
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) > Technical Advice Memoranda. Coverage begins in 1954.

IRS Technical Memoranda
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) > Technical Memoranda. Coverage from 1967-1993´╗┐.

Print

IRS Letter Rulings CCH
Library has 1977-1993, 2004-2009. Index coverage, 1977-1999. Indexed by Subject and Code Section. See Transfer Binders. For rulings from 1977-1993, see Microforms.

IRS Positions Reporter CCH
1982 - present. For 1982-2013, see Transfer Binders.

Standard Federal Tax Reporter CCH
Library has 1951 - present. Current year in General Collection; older years in Historic. See Finding Lists, General Counsel's Memoranda.