{"id":"GOV-004","kind":"gov","level":"law","jurisdiction":"United States","state":"","metro":"","industry":"","agency":"","eco":"","issuer":"","authority":"","instrument":"Office of Chief Counsel, IRS, Memorandum AM 2023-007 (Oct. 18, 2023; released Nov. 3, 2023), \u0027Issues Related to Whether an Employer Experienced a Full or Partial Suspension... Due to Communications from the Occupational Safety and Health Administration\u0027","title":"Office of Chief Counsel, IRS, Memorandum AM 2023-007 (Oct. 18, 2023; released Nov. 3, 2023), \u0027Issues Related to Whether an Employer Experienced a Full or Partial Suspension... Due to Communications from the Occupational Safety and Health Administration\u0027","dateIssued":"2023-10-18","effective":"","end":"","startDate":"2023-10-18","endDate":"","quarters":[],"types":[],"addressees":[],"clause":"","enforcement":"","functions":[],"notes":"Exhibit p. 12: \u0027If an employer maintains that modifications had more than a nominal effect on the employer\u0027s trade or business operations, the employer needs to substantiate that the modifications resulted in a reduction in an employer\u0027s ability to provide goods or services in the normal course of the employer\u0027s business of not less than 10 percent to fall within the provisions of Notice 2021-20.\u0027 Exhibit p. 1: \u0027This GLAM may not be used or cited as precedent.\u0027 This is the Oct. 18, 2023 memorandum the Opening Brief quotes at 11 (3-ER-505) and identifies as \u0027IRS GLAM 2023-007\u0027 (Opening Br. at 44 n.6). Tri-State at 11-12 treats a GLAM as non-precedential by its own terms.","sourceUrl":"https://www.irs.gov/pub/lanoa/am-2023-007.pdf","snapshot":"","fileExists":true,"fileBytes":238880,"grade":"primary","character":"","description":"","collection":"GOV","url":"/library/GOV-004","exhibitUrl":"/exhibit/GOV-004","citation":"Office of Chief Counsel, IRS, Memorandum AM 2023-007 (Oct. 18, 2023; released Nov. 3, 2023), \u0027Issues Related to Whether an Employer Experienced a Full or Partial Suspension... Due to Communications from the Occupational Safety and Health Administration\u0027 (Ex. GOV-004)","stateName":"","related":[]}