Aren't most the contradictions forms of ambiguity? Two overlapping scenarios where some sort of administrative ruling is needed to clarify which dominates. Does that count as contradiction? https://www.irs.gov/irb is full of this kind of stuff.
I don't think so, at least not in the logical sense (an ambiguity means that the terms need to be refined to produce a decision, whereas a contradiction means that no decision exists).
(Maybe this distinction is silly, but I think it's important: ambiguity is inevitable, but asserting that the IRS knowingly maintains contradictory rules suggests some kind of sovereign-citizen-adjacent thinking.)
No, I was not proposing such situations are knowingly maintained, explicitly the opposite: there is a whole system to resolve them once discovered. Here is an example I found in the first bulletin I clicked on, but each one is full of examples like this: https://www.irs.gov/irb/2023-50_IRB
In this case, you have ambiguity in a definition of "partner assets and liability" in that, it could be read to include factor X and Not-X, and thus was contradictory. Resolving the definition to be more clear remove the problem inherent in rule.
> regulations provided that, in any taxable year, a partner’s share of each asset and liability of a section 987 aggregate partnership was proportional to the partner’s liquidation value percentage with respect to the aggregate partnership. A partner’s liquidation value percentage was defined as the ratio of the liquidation value of the partner’s interest in the partnership to the aggregate liquidation value of all the partners’ interests in the partnership.
> recommended that §1.987-7 be withdrawn and replaced with the approach of the 2006 proposed regulations under section 987, which provided that a partner’s share of assets and liabilities reflected on the books and records of an eligible QBU held indirectly through the partnership must be determined in a manner consistent with how the partners have agreed to share the economic benefits and burdens corresponding to those partnership assets and liabilities, taking into account the rules and principles of subchapter K. A comment indicated that the liquidation value percentage approach was inconsistent with certain principles of subchapter K, resulting in distortions in the calculation of section 987 gain or loss in certain cases.
So the prior guidance (in different documents, likely authored by different people) suggested two different mechanisms that are in conflict, resulting in different calculations. The latest guidance resolved this favor of an approach that clarifies what is actually allowed (In this case, rescinding the prior rule, but allowing either approach provided that approach was applied with internal consistency)
