tag:blogger.com,1999:blog-1519969502186924526.post3647454177499802044..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: IRS Queasiness Over the Reaches of Allen (9/22/12)Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger3125tag:blogger.com,1999:blog-1519969502186924526.post-70091249626124694552012-09-27T07:06:12.719-05:002012-09-27T07:06:12.719-05:00Researcher,
I think that is right. Within the I...Researcher,<br /><br /><br />I think that is right. Within the IRS, I think that agents and other nonlawyer personnel will be influenced by it and, institutionally, the IRS may have some type of stare decisis attitude about them -- that issues been dealt with and decided, so why change. But, the ILM like other informal statements are not afforded great weight by courts in interpreting the law. I am going to use some jargon here, but bear with me. Perhaps a court would give some weak form of deference -- sometimes called Skidmore deference -- to a legal interpretation in such a document, but I think it would be a very weak form of deference. And Skidmore itself is a weak form of deference -- i.e., you defer only if the position is persuasive. Well, if the position is persuasive, then the persuasiveness should perhaps carry the day. But, to directly answer the question I think you are asking, the "standing" is very little and perhaps none.<br /><br /><br />Jack TownsendJackTownsendnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-45148042183111708842012-09-27T06:45:23.366-05:002012-09-27T06:45:23.366-05:00Jack
What is the standing of an internal legal me...Jack<br /><br />What is the standing of an internal legal memorandum from the IRS beyond the specific party's case ? I presume it is not 'official', but gives some idea of the Chief Counsel's thinking on a matter, somewhat like a Private Letter Ruling ?Researchernoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-24575182124877792842012-09-25T23:57:03.931-05:002012-09-25T23:57:03.931-05:00
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