Category of Comprehensive Written Decisions: A set of official rulings on various matters, each containing a detailed explanation of the decision-making process.
The Internal Revenue Service (IRS) and the Department of the Treasury make a variety of documents, including rulings, determination letters, technical advice memoranda, and Chief Counsel Advice, available for public inspection. These types of documents fall under the category of determinations and rulings, which are marked as CUI//SP-WDT.
These documents can primarily be accessed through official IRS and Department of the Treasury channels. The IRS regularly publishes determination letters and rulings on its official website, particularly under the "Tax Exempt and Government Entities" and "Private Letter Rulings and Technical Advice" sections.
Technical Advice Memoranda (TAMs) and Chief Counsel Advice (CCA) documents are generally available via the IRS Chief Counsel's published archives or Freedom of Information Act (FOIA) reading rooms.
The public disclosure of certain written determinations, such as rulings and advice, is mandated by 26 USC 6110, subject to confidential taxpayer information redactions. These released documents are often posted on the IRS website or made available through third-party legal research databases.
For CUI//SP-WDT (Controlled Unclassified Information / Sensitive but Unclassified - Withhold Data Taxpayer) markings, such documents may have disclosure restrictions, but redacted versions suitable for public access should be obtainable.
To locate the exact documents, you can start at the IRS FOIA Reading Room, a key repository for IRS rulings and advice documents. Alternatively, you can use the IRS website's Tax Rulings & Agreements page to browse or search for determination letters or rulings. Additionally, legal research databases like Tax Notes, CCH, or Bloomberg Tax offer comprehensive collections of rulings and memoranda subject to 26 USC 6110.
It is important to note that the withholding of certain types of data is regulated by Treasury Regulation 301-6110, and the sanctions for non-compliance with 26 USC 6110 are outlined in 26 USC 6110(j), 26 USC 7213, 26 USC 7213A, and 26 USC 7431.
In conclusion, while finding these documents may require some effort, official IRS resources and specialized tax law databases provide a reliable path to accessing publicly available IRS documents.
In the pursuit of business-related financial information, one can primarily access determination letters and rulings on the IRS's official website, particularly under the "Tax Exempt and Government Entities" and "Private Letter Rulings and Technical Advice" sections. Additionally, technical advice memoranda (TAMs) and Chief Counsel Advice (CCA) documents are available via the IRS Chief Counsel's published archives or Freedom of Information Act (FOIA) reading rooms.
