Question

What is an IRS Announcement?  When is it used?  In your opinion, could a tax practitioner rely on an IRS Announcement as authority for a tax return position? Would your answer change at all if we are talking about an IRS Notice?

Answer 1

IRS Announcements concern items of general importance to taxpayer.they are public pronouncements that have immediate or short term value such as an approaching deadline for making an election

Notices contain guidance involving substantive interpretations of the Code or other provisions of the law ususally have long term application.

A tax practitioner may rely on an IRS announcement or notice as an authority for an action but should confirm understanding of the released material using appropriate research techniques