|
|
|
|
IRS General Counsel Memoranda
FILE-NAME: GCM
COVERAGE: From March 1967 through November 2002; Selected documents available from October 1958 through March 1967.
FREQUENCY: As received from the agency
UPDATE-SCHEDULE: Updated regularly - Atypical update schedule/as received from the agency
CONTENT-SUMMARY:
IRS General Counsel Memoranda (GCM file) are documents issued by the Internal Revenue Service (IRS) General Counsel in response to legal questions asked by the IRS staff.
PUBLISHER:
Internal Revenue Service
SEGMENT-DESCRIP: | ACTION-DOC | The ACTION-DOC segment contains information which relates to the underlying document. | | | ACTION-DOC (revenue ruling) | | | | | CITE | The CITE segment contains the unique citation of the document, and also a LEXIS cite. | | | CITE (1990 GCM LEXIS 31) or CITE (G.C.M. 39835) | | | | | DATE | The DATE segment contains the date when the GCM was issued. This segment is arithmetically searchable. | | | Date=2002 | | | | | REFERENCE | The REFERENCE segment contains the internal IRS number assigned to the document. | | | REFERENCE (216-90) | | | | | TEXT | The TEXT segment contains the full-text of a document. | | | TEXT (medicare costs) | | | |
DOC-DESCRIPTION:
Each memoranda represents a document.
DISPLAY-SEQUENCE:
Documents display in reverse chronological order.
USE-TIPS:
To find General Counsel Memoranda which discusses excise tax imposed by section
4976(a) of the code, ENTER:
excise tax w/10 section 4976 a
HIER-LOC:
Area of Law - By Topic/Accounting/Access Directories/Tax Center/Federal/Primary/IRS
Area of Law - By Topic/Accounting/Find Statutes, Regulations & Administrative Materials/By Subtopic/Pensions & Benefits/Find Administrative Materials
Area of Law - By Topic/Accounting/Find Statutes, Regulations & Administrative Materials/By Subtopic/Taxation/Find Federal Administrative Materials/Agency Decisions
Area of Law - By Topic/Administrative Law/Find Specific Agency Decisions & Materials/Tax - Federal
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Health Care
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Human Resources/Agency Decisions
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Medical
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Pensions & Benefits
Area of Law - By Topic/Federal Practice/Find Statutes, Regulations, Administrative Materials & Court Rules/Adminstrative Agency Materials/Taxation/Agency Decisions
Area of Law - By Topic/Financial Crisis Litigation/Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Taxation/Find Federal Administrative Materials/Agency Decisions
Area of Law - By Topic/Financial Services Industry - Critical Issues/Related Industries View/Pensions & Benefits/Research and Assess Issues/Find Administrative Materials
Area of Law - By Topic/Human Resources/Find Administrative Materials/Federal/Agency Decisions
Area of Law - By Topic/Pension & Benefits/Find Administrative Materials
Area of Law - By Topic/Taxation/Find Federal Administrative Materials/Agency Decisions
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Health Care
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Human Resources/Agency Decisions
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Medical
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Pensions & Benefits
Federal Legal - U.S./Find Statutes, Regulations, Administrative Materials & Court Rules/Administrative Agency Materials/Taxation/Agency Decisions
SAMPLE-DOC:
This document is not to be relied upon or otherwise cited as precedent by taxpayers.
General Counsel Memoranda 39892
SECTION 1485
PSI:8:PSKirwan 1485-6602
-- CC:PRENO 1485-6602
GCM 39892; 2002 GCM LEXIS 1
November 26, 2002
[*1]
UI LIST:
UI No. 1485-6602
UI No. 1485-6602
TEXT:
GCM 35151, Revocation of
Heather C. Malloy
Associate Chief Counsel (Passthroughs and Special Industries)
Application of Failure to Pay Penalty, GCM 35151,1-4848 (December 7, 1972), which held that a person paying an amount subject to the ? 4251 telephone excise tax that refuses to pay tax is subject to the addition to tax under ? 6651(a)(3), is revoked. The analysis and holding of the GCM are inconsistent with ? 6501(b)(4).
Ruth Hoffman, Senior Technician Reviewer, Branch 8, Associate Chief Counsel (Passthroughs and Special Industries)
|
|
