These documents are prepared by field attorneys in the Office of Chief Counsel, reviewed by an Associate Office, and subsequently issued to field or service center campus employees of the Internal Revenue Service. Note: These items cannot be used or cited as precedent. 2019 20193001F — Consent to Extend Time to Assess Tax for Tax Years PDF 2018 20184201F — I.R.C. § 1311 PDF 20183701F — Request for Advisory Opinion PDF 20182502F — Commitment Fees PDF 20182501F — Allocation of DPGR and non-DPGR PDF 20182101F — Review of Proposed Notice of Deficiency PDF 20181701F — Anti-Churning Rules PDF 20181601F — AMT Preference Item- IDC and Hedging Income PDF 20181201F — I.R.C. § 54E PDF 20180601F — Section 481(a) Issue PDF 20180101F — Section 1.451-4 PDF Related topic Legal Advice Issued by Field Attorneys
