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General Counsel Memoranda (GCM)

 

The following list 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:

It is important to note that such items cannot be used or cited as precedent.

  • GCM 39893  Revokes GCM 39542, which addressed the Non-Tax Refund Offset Program.

  • GCM 39891  Revokes GCM 39865, TR-45-1437-90 (Dec. 12, 1991), since it is contray to the holding of the Tax Court in Ohio Farm Bureau Federation, Inc. v. Commissioner, 106 T.C. 222 (1996).

  • GCM 39892  Revokes GCM 35,151,1-4848 (December 7, 1972), since the analysis and holding of the prior GCM are inconsistent with IRC § 6501(b)(4).

  • GCM Issue Index II  A list of GCMs arranged by Internal Revenue Code and Regulations issues, as found in Publication 1102, Uniform Issue List.