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June 15, 2026Journal of the American Taxation Association

GCMs TMs and AODs--The 'Working Law' of the internal Revenue Service.

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Authors

MGMichael G. Gallagher

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Overview

Legal documents clarify IRS policies in taxation, suggesting their potential importance for tax analysis.

Key Points

  • To investigate the impact of recently released IRS memoranda on tax research and legal precedents.
  • Analysis of memoranda obtained from a freedom-of-information lawsuit.
  • Assessment of the IRS's position on the citation of these documents.
  • Memoranda provide insights into IRS policies, enhancing understanding of tax issues.
  • IRS asserts these documents cannot be cited by taxpayers as precedents, leaving their legal status open for court interpretation.

Cite This Study

Michael G. Gallagher (1984) studied this question.

synapsesocial.com/papers/6a2f96eca1cfeec490828146https://doi.org/10.2308/jata-6149195
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