Discuss the precedential value of private letter rulings, determination letters, and technical advice memoranda. What role do these items play in conducting tax research?

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Hill

30 July, 09:27

Discuss the precedential value of private letter rulings, determination letters, and technical advice memoranda. What role do these items play in conducting tax research?

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Rashad Ochoa · Answer 1

The documents may not be used or cited by the taxpayer or IRS personnel. On the contrary, the letter rulings and other necessary documents may be cited or used as evidence for similar situations such as PRLs TAM to prevent the penalties of tax. This is essential to ensure that the relevant information is properly documented.

Explanation:

The documents may not be used or cited by the taxpayer or IRS personnel. On the contrary, the letter rulings and other necessary documents may be cited or used as evidence for similar situations such as PRLs TAM to prevent the penalties of tax. This is essential to ensure that the relevant information is properly documented.