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Dec
The IRS Office of Chief Counsel on Dec. 20, 2019, released a so-called Generic Legal Advice Memorandum (GLAM) that had been issued to Division Counsel within the IRS Tax Exempt and Government Entities Division. A GLAM is not binding authority and cannot be used or cited as precedent, but it does provide important insight as to how the IRS views a particular issue, as well as how that issue is likely to be analyzed by an IRS auditor.
In GLAM 2019-003,...