GENERAL COUNSEL’S MEMORANDUM

General Counsel’s Memorandum.Tax law. 1. A written discussion, issued by the office of the

Chief Counsel of the IRS, on the merits of a legal issue involving tax law. 2. A written explanation,

issued by the office of the Chief Counsel of the IRS, explaining the IRS’s positions in revenue

rulings and technical advice memorandums. [Cases: Internal Revenue 3051.] [Blacks Law 8^th]