General Counsel’s Memorandum [Tax Law] Law and Legal Definition

General counsel’s memorandum refers to a written document issued by the chief counsel of the Internal Revenue Service (IRS). The memorandum explains the merits of a legal issue involving tax law and the IRS’s position in revenue rulings. The general counsel’s memorandum is treated as an informal document. It also provides the chief counsel's opinion on particular tax matters before other IRS officials. The general counsel’s memorandum is entitled to some deference, although it does not have the force of law because it is not generally subject to notice and comment. [Nathel v. Comm'r, 2010 U.S. App. LEXIS 11244 (2d Cir. 2010)].