What is the primary function of a memorandum issued by the Chief Counsel?

The primary function of a memorandum issued by the Chief Counsel is to address issues that are applicable to a general class of taxpayers. These memoranda are designed to provide guidance on the interpretations of tax laws, regulations, or policies that can affect a broader range of taxpayers, rather than focusing on individual cases.

By producing these general guidance documents, the Chief Counsel aims to standardize the approach to specific issues and assist IRS agents and tax professionals in applying the law consistently across various cases. This helps ensure that similar circumstances are treated uniformly, thereby promoting fairness and clarity within the tax system.

Other types of documents, such as those addressing specific taxpayers or providing recommendations for amendments to tax returns, do not fulfill the general guidance purpose that the Chief Counsel's memorandum is intended to achieve.