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.
NYC Tax Advocates
- Payroll & Sales Tax & Workers Comp Audit Representation
- 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.
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Selig & Associates is a boutique Tax Representation and Risk Management Firm specializing in unpaid tax obligations and commercial insurance coverage
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