Technical Advice Memorandum

Guidance by the Office of Chief Counsel of the IRS at the request of an IRS director, area director, or appeals office, in response to technical or procedural questions developed during a specific taxpayer proceeding. Generally, a TAM is only issued as to closed transactions; interprets tax laws, treaties, regulations, revenue rulings, or other precedents; and represents a final determination of the position of the IRS as to the specific taxpayer matter.