What is a Technical Advice Memorandum?

A Technical Advice Memorandum (TAM) is indeed a ruling issued by the IRS national office. This type of memorandum provides specific guidance to IRS agents and helps them resolve complex tax issues that arise during audits or other inquiries. It is important to note that a TAM is not a binding precedent; however, it is intended to provide clarity and consistency in the application of tax law across similar cases.

This process ensures that IRS officials have a reliable source of technical advice on matters that require interpretation of tax law or IRS regulations, thereby aiding in effective tax administration. The nature of a TAM distinguishes it from rulings issued by tax courts, which address legal disputes brought before them, and general IRS publications, which offer broad information intended for a wider audience. Additionally, while guidances like TAMs serve taxpayers indirectly by contributing to the consistency of IRS practices, they are not designed as direct guidelines for taxpayer use.