Private letter rulings, technical advice memoranda, Chief Counsel advice and similar documents published by the IRS have no value as precedent and are generally treated in litigation with the IRS as entitled to no more weight than a position advanced by the Commissioner on a brie. See, e.g. Laglia V. Commissioner, 88 T.C. 894, 897 (1987). Moreover, Internal Revenue Code section 6110(d)(3) provides that a "written determination" may not be "used or cited as precedent". Internal Revenue Code Section 6110(b)(1) defines the term "written determination" as a "ruling, determination letter, technical advice memorandum, or Chief Counsel advice".
However, these private letter rulings are often helpful in understand the position of hte IRS with respect to the issues addressed. The Chief Counsel advice does have weight within the IRS; it is viewed as written advice or instruction which conveys an interpretation of a revenue provision or IRS position.
Recent developments seem to indicate that the IRS will issue a new CCA stating that RDPs will have a choice for 2010 as to whether to split their community income, or report all of their own income on their returns. This is based on communications from the IRS Tax Forms and Publications division. 
The following Lambda Legal bulletins and the IRS publication noting the new IRS positions are linked here for further information:
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