Internal Revenue Manual (CCDM) 32.2.2, Publication of Rulings and Other Guidance; 32.2.2.10 (08-11-2004), 'Force and Effect of Revenue Rulings, Revenue Procedures, Notices, Announcements, and News Releases', paragraphs (3)-(4), page as read Sept. 26, 2026

HTML sha256 0117f7e9edf8a2182a38f670feaeff2edf87f8e9c1621343c316d3f301c6e2dc. Text read: '(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.' The section header on the page reads '32.2.2.10 (08-11-2004)'; Cite the paragraph, not a date, or cite both.