{"id":"LAW-034","kind":"law","level":"law","jurisdiction":"","state":"","metro":"","industry":"","agency":"","eco":"","issuer":"Internal Revenue Service, Office of Chief Counsel","authority":"IRM (CCDM) 32.2.2, Published Guidance and Other Guidance to Taxpayers, sec. 32.2.2.10(3)-(4)","instrument":"IRM (CCDM) 32.2.2, Published Guidance and Other Guidance to Taxpayers, sec. 32.2.2.10(3)-(4)","title":"IRM (CCDM) 32.2.2, Published Guidance and Other Guidance to Taxpayers, sec. 32.2.2.10(3)-(4)","dateIssued":"2004-08-11","effective":"","end":"","startDate":"2004-08-11","endDate":"","quarters":[],"types":[],"addressees":[],"clause":"(3)... all notices and announcements issued by the Service and published in the IRB are considered authority and the Service is bound by the substantive or procedural guidance provided in a notice or announcement to the same extent as a revenue ruling or revenue procedure. See Rev. Rul. 90-91, 1990-2 C.B. 262. (4) Chief Counsel attorneys must follow legal positions established by publications in papers filed in Tax Court or in defense letters or suit letters sent to DOJ. Chief Counsel attorneys may not rely on case law to take a position that is less favorable to a taxpayer in a particular case than the position set forth in a publication.","enforcement":"","functions":[],"notes":"Rendered page as displayed Sept. 26, 2026. The section header reads \u002732.2.2.10 (08-11-2004)\u0027; \u002704-14-2017\u0027 appears only in the page-level Manual Transmittal block.","sourceUrl":"https://www.irs.gov/irm/part32/irm_32-002-002","snapshot":"","fileExists":true,"fileBytes":347868,"grade":"primary","character":"IRS manual","description":"","collection":"LEG-A","url":"/library/LAW-034","exhibitUrl":"/exhibit/LAW-034","citation":"Internal Revenue Service, Office of Chief Counsel, IRM (CCDM) 32.2.2, Published Guidance and Other Guidance to Taxpayers, sec. 32.2.2.10(3)-(4) (Aug. 11, 2004) (Ex. LAW-034)","stateName":"","related":[]}