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As announced in
August 2008, the Department has transferred responsibility for Advisory
Opinions from the Taxpayer Guidance Division to the Department's Office of
Counsel. Among other changes, the format of the Advisory Opinions issued by
the Office of Counsel will appear slightly different than the format used by
the Taxpayer Guidance Division. During the transition period, which began in
2008 and is scheduled to be completed in 2009, the Department will issue
Advisory Opinions in two formats. Those opinions issued by the Taxpayer
Guidance Division will continue in the previous format, while opinions
written by Office of Counsel will be issued in the revised format. One of
the most noticeable changes in format is that the opinions issued by the
Office of Counsel, for petitions received on or after August 8, 2008, will
not contain the petitioner’s name, address, or identification numbers when
posted on the Department's Web site. Both formats are official Advisory
Opinions, and all are binding on the Department with respect to the person
or entity to whom they are issued and the facts stated in the Opinion. For
more information on the transition and the procedures, see
TSB-M-08(10)C,
(5)I, (5)M, (3)R, (8)S, Changes in Procedures for Obtaining Guidance
from the Tax Department. |
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