Which of the following is a type of Precedential Authority binding the IRS?

Court opinions represent a type of precedential authority that binds the IRS. Court decisions, particularly from higher courts such as the U.S. Supreme Court and the U.S. Court of Appeals, set legal precedents that the IRS must follow in future cases. These rulings are significant because they interpret tax laws and can provide binding guidance on how the law should be applied, which serves to ensure consistency and reliability in tax administration.

In contrast, private letter rulings, technical advice memoranda, and the Internal Revenue Manual are not considered binding precedential authority. Private letter rulings are specific to the requesting taxpayer and do not establish precedent for other cases. Technical advice memoranda are issued in response to requests for guidance on specific tax matters but do not serve as binding authority. The Internal Revenue Manual serves as a guide for IRS personnel and outlines procedures, but it is not legally binding in the way that court rulings are. Therefore, the only option that constitutes binding precedential authority is court opinions.