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Legal Advice Issued to Program Managers

These documents are legal advice, signed by attorneys in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers. They are issued to assist Service personnel in administering their programs by providing authoritative legal opinions on certain matters, such as industry-wide issues.

2012 | 2011 | 2010 | 2009 | 2008 | 2007

NOTE: These documents cannot be used or cited as precedent.
Document Number Subject Uniform Issue List (UIL) Codes
PMTA-2012-19 Effect of Late Notice in Chapter 13 09.00.00-00
PMTA-2012-18 Retail Tax on Imported Leased Trucks 4051.00-00
PMTA-2012-17 Black Liquor and Cellulosic Repayments 87.00-00,
6601.00-00
PMTA-2012-16 Accuracy-Related Penalty on Underpayments - Frozen Refundable Tax Credits 6664.01-00,
6662.00-00
PMTA-2012-15 Disclosure Issues Related to Changes in Procedures for Requesting Certified Copies of Bank Secrecy Act Records 6103.09-01
PMTA-2012-14 Collection Appeal Program and I.R.C. § 6330(c)(4) Issue Preclusion 6330.00-00
PMTA-2012-13 Resolution of Identity Theft Cases Where the Service Issued a Statutory Notice of Deficiency 6212.00-00
PMTA-2012-12 Credit Interest Order of Allocation 6611.00-00,
6611.01-02
PMTA-2012-11 Dropping Cents from Form 941 6102.00-00
PMTA-2012-10 Scope of Awards Payable under I.R.C. Section 7623 7623.00-00
PMTA-2012-09 Interest Suspensions and Form 906 Closing Agreements 6601.09-00
PMTA-2012-08 Certain Liquids as Alternative Fuels 6426.00-00
PMTA-2012-07 State Access to TIN Matching Database for Tax Administration 6103.04-01
PMTA-2012-06 Interstate Child Support Access to Federal Tax Information 6103.12-06
PMTA-2012-05 Disclosure Issues Related to Identity Theft 6103.00-00
PMTA-2012-04 Including taxpayer identification numbers on Form 872-AP, Consent to Extend the Time on Assessment of IRC Section 6695A Penalty 6103.08-04
PMTA-2012-03 Trespass 9999.00-00
PMTA-2012-02 Credit Interest on Overpayments When Carryback Recaptures Arise 6611.00-00,
6611.01-02
PMTA-2012-01 Tax Treatment of Payments Made Pursuant to Programs M and N. 108.00-00,
108.05-00

2012 | 2011 | 2010 | 2009 | 2008 | 2007

Page Last Reviewed or Updated: 2013-04-11