LibGuides: Tax Law Research : Federal and Ohio: Memoranda

Introduction

IRS Memoranda are part of the Legal Advice Program of the IRS. They are meant as guidance to IRS employees. They include General Counsel Memoranda, Chief Counsel Notices (formerly called Litigation Guideline Memoranda) and Technical Memoranda. They are now mostly subsumed under the Chief Counsel Advice nomenclature now.

Kinds of IRS Memoranda

Chief Counsel's Directives Manual (CCDM)
The Chief Counsel Directives Manual (CCDM), published as Parts 30 through 39 of the Internal Revenue Manual, is the authoritative statement of policy and guidance for the IRS Office of Chief Counsel on matters covered therein.
While some parts and sections of the CCDM may contain specific procedures, it is not a comprehensive checklist for every action. Step-by-step guides may be developed outside of the CCDM. The principal intent of the CCDM is to clearly and concisely reflect Chief Counsel policy for the effective operation of the Chief Counsel organization.
Chief Counsel Notices
Formerly called Litigation Guideline Memoranda (LGM). Chief Counsel (CC) Notices are directives that provide interim guidance, furnish temporary procedures, describe changes in litigating positions, or announce administrative information. Notices providing interim guidance or instructions to staff are designed to be incorporated into the Chief Counsel Directives Manual (CCDM), but are issued as Notices to provide immediate notification of important policy or procedural changes.

Westlaw provides access to Litigation Guideline Memoranda from 1988 - 2000 (with one extra document being issued in 2001), with a few memoranda from 1976 through 1987. Lexis Advance provides them for 1986-1999. Westlaw provides access to IRS Chief Counsel Advisories beginning in 1999 and Chief Counsel Notices from 1995 - present. Lexis Advance appears to provide access to Chief Counsel Notices through its Chief Counsel Advice database from 1998 - present.

General Counsel Memoranda (GCM)
The IRS website provides documents prepared by the Office of Chief Counsel that the Office has determined should be made available to the public, due to the nature of their subject matter.
Legal Bitstream. com
Technical Memoranda are documents prepared by the Office of the Chief Counsel that explain the reasons behind the adoption of a Treasury Decision”. Select Memoranda are available on this website.

Lexis Advance and Westlaw provide coverage of Technical Memoranda from 1967-1993, when they ceased to be published as Memoranda. They are now part of Chief Counsel Advice.

TAMS from Tax Notes Today