Court Rules that IRS Not Bound by Field Service Advice (FSA) – Taxpayers Cannot Rely Upon Them Either

December 13, 2007
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Roger McEowen

Abstract

In a recent case, a federal district court ruled that IRS is not bound by agency-issued FSAs, and that IRS need not treat similarly situated taxpayers similarly.   In its opinion, the court pointed out the difference between an FSA and a private letter ruling, and sounded a warning to taxpayers attempting to rely on FSAs for a position taken on a return.  The case also points out that attempting to bind IRS to an FSA may be difficult, if not impossible.

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