NYC Tax Advocates

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Specializing in IRS and NYS Tax Representation. Workers Compensation Audits, Payroll, Sales and Income Tax representation for Businesses, Individuals, Restaurants and Construction Companies. Civil and Criminal Workers Comp Audit representation includes: NYSIF Examinations, Premium Disputes, Employee Misclassification, Underreporting, Unreported Income, and Failure to Keep Accurate Payroll Records.

Tuesday, January 24, 2017

What the Hell is an IRS Technical Advice Memorandum

Technical Advice Memorandums, colloquially called TAMs, are similar to PLRs but rear their ugly heads during the course of a proceeding before the IRS (including audits or before the IRS appeals division).  A TAM may be requested by an IRS employee responsible for examining a taxpayer’s return (or a taxpayer may request that a particular issue be referred to the Chief Counsel’s Office for technical advice, which is an extremely powerful tool).  A TAM may not be requested for hypothetical transactions.  Additionally and like a PLR, TAMs cannot be cited for precedence.

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