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APPENDIX Aprivate letter ruling, or technical advice memorandum, the IRS National Officemay seek legal advice from its Office of Chief Counsel; the resulting advice isprovided in the form of a chief counsel advice memorandum. These documentsare eventually made public, albeit in redacted form.Private letter rulings and technical advice memoranda for years were identifiedby seven-digit numbers, as in “Priv. Ltr. Rul. 9826007” (see, e.g., Chapter 3,note 71). (A reference to a technical advice memorandum appears in Chapter 3,note 89.) Beginning in 1999, however, the IRS began using a nine-digit numberingsystem, as in “Priv. Ltr. Rul. 199926007 (e.g., Chapter 3, note 226). The first fournumbers are for the year involved (here, 1999), the second two numbers reflectthe week of the calendar year involved (here, the 26th week of 1999), and theremaining three numbers identify the document as issued sequentially duringthe particular week (here, this private letter ruling was the seventh one issuedduring the week involved). General counsel memoranda (now Ch. Couns. Adv.Mem.) are numbered sequentially in the order in which they are written (e.g.,Gen. Couns. Mem. 39457 is the thirty-nine thousand, four hundred fifty-seventhgeneral counsel memorandum ever written by the IRS’s Office of Chief Counsel.)A reference to a general counsel memorandum appears in Chapter 3, note 167.The IRS also issues technical expedited advice memoranda, which will replacesome technical advice memoranda; these are intended to produce requestedadvice within a shorter period. In the tax-exempt organizations area, the IRS wasordered by a federal court of appeals in 2004 to release rulings denying or revokingexempt status; these are termed exemption denial and revocation letters.The JudiciaryThe federal court system has three levels: trial courts (including those that initiallyhear cases when a formal trial is not involved), courts of appeal (appellatecourts), and the U.S. Supreme Court. The trial courts include the various federaldistrict courts (at least one in each state, the District of Columbia, and theU.S. territories), the U.S. Tax Court, and the U.S. Court of Federal Claims (formerlythe U.S. Claims Court). There are 13 federal appellate courts: the U.S.Courts of Appeals for the First through the Eleventh Circuits, the U. S. Court ofAppeals for the District of Columbia, and the U.S. Court of Appeals for theFederal Circuit.Cases concerning the tax law of charitable giving at the federal level canoriginate in any federal district court, the U.S. Tax Court, or the U.S. Court ofFederal Claims. Under a special declaratory judgment procedure available onlyto charitable organizations (IRC § 7428), cases can originate only with the U.S.District Court for the District of Columbia, the U.S. Tax Court, or the U.S. Courtof Federal Claims. Cases involving tax-exempt organizations are considered bythe U.S. courts of appeal and the U.S. Supreme Court.Most opinions emanating from a U.S. district court are published by theWest Publishing Company in the Federal Supplement series (F. Supp.). Thus, acitation to one of these opinions appears as “[number] F. Supp. [number],” followedby an identification of the court and the year of the opinion. The firstnumber is the annual volume number; the second number is the page in thebook on which the opinion begins (see, e.g., Chapter 1, note 35). (In early 1998, 644