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Chase 3L Contributes to Technical Advice Memorandum
Dawn Danley-Nichols
Dawn Danley-Nichols

Apr 09, 2009 - Chase 3L Dawn Danley-Nichols worked on an IRS National Office Technical Advice Memorandum (TAM) while interning this past summer in the Cincinnati office of the IRS Chief Counsel. The Technical Advice Memorandum (TAM 200914022) dealt with the limitation under IRC §381(c)(22) on the use of discounted unpaid losses by a parent corporation of an insurance subsidiary. A redacted version of the TAM can be found on Westlaw or Lexis under "TAM 200914022."

"It was a complex corporate tax problem; therefore, I felt very fortunate to be included in the process and trusted by senior Counsel attorneys to help present this issue to the National Office," said Danley-Nichols.

A technical advice memorandum, or TAM, is guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director, appeals, in response to technical or procedural questions that develop during a proceeding. Technical Advice Memoranda are issued only on closed transactions and provide the interpretation of proper application of tax laws, tax treaties, regulations, revenue rulings or other precedents.