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.