Announcements “. . . alert taxpayers to a variety of information but do not have the formality of notices, revenue rulings, or revenue procedures. They constitute authority for avoiding the substantial understatement penalty” [under I.R.C. § 6662]. Gail Richmond, Federal Tax Research: Guide to Materials and Techniques, p. 95 (5th ed. 1997)(Foundation Press). “[Notices and Announcements] may . . . contain substantive guidance regarding the tax laws or contain guidance to taxpayers of a procedural nature. Generally, Notices and Announcements are used when expeditious guidance is needed. Since Notices and Announcements that contain substantive or procedural guidance are intended to be relied on by taxpayers, they are the equivalent of revenue rulings and revenue procedures . . . .” Rev. Rul. 87-138, 1987-2 C.B. 287.
Mortgage w/2 Interest
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