Substantial Authority
Substantial Authority means, in evaluating a taxpayer's position on an issue, any of the following:
• the Internal Revenue Code and other statutes.
• Treasury Regulations (proposed, temporary, and final).
• Revenue rulings and revenue procedures.
• tax treaties.
• court cases.
• congressional intent (e.g., committee reports).
• General explanations prepared by the Joint Committee on Taxation (the Blue Book).
• private letter rulings (PLR) and technical advice memoranda (TAM) issued after October 31, 1976.
• actions on decisions (AOD) and general council memoranda (GCM) issued after March 12,1981.
• U.S. Internal Revenue Service information and press releases.
• notices, announcements, and administrative pronouncements from the U.S. Internal Revenue Service (IRS) (published in the Internal Revenue Bulletin).
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