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An IRS Technical Advice Memorandum applies strictly to the taxpayer for whose audit it was requested and cannot be relied upon by other taxpayers

User SstrykerR
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Final answer:

An IRS Technical Advice Memorandum (TAM) is a document specific to an individual taxpayer's audit, providing guidance on tax laws for their situation, and cannot be used as precedent by others.

Step-by-step explanation:

An IRS Technical Advice Memorandum, or TAM, is a document issued by the Internal Revenue Service upon the request of an auditor to resolve a complex tax issue during an audit. The TAM is intended to provide guidance on the proper interpretation and application of tax laws to the specific facts of the taxpayer's situation. As such, it is legally binding on the taxpayer and the IRS with respect to the tax periods and issues covered in the audit. However, it is important to note that TAMs cannot be used as precedent by other taxpayers. This is because TAMs are fact-specific and are not official pronouncements of law or the IRS's position on more general legal issues.

User Evan Benn
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