835 authority exercise fall 2019.doc - Xiaomin Zhang F229C562 Acct 835 Authority Exercise Fall 2019 1 Describe the general contents of each of the

835 authority exercise fall 2019.doc - Xiaomin Zhang...

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Xiaomin Zhang F229C562 Acct. 835 Authority Exercise Fall 2019 1. Describe the general contents of each of the following in the Internal Revenue Code a) Sec. 61 Gross Income Defined b) Sec. 162 Trade or Business Expenses c) Sec. 212 Expenses for production of income 2. Describe the purpose of and the structure of a typical Revenue Ruling. Revenue Ruling are second to regulations as important administrative sources of the federal tax law. A revenue ruling is an official pronouncement of the National Office of the IRS. It deals with the application of the IRC and regulations to a specific factual situation. In addition, revenue rulings provide taxpayers with needed information, such as applicable federal interest rates and other items required by tax-payers. The structure of a typical Revenue Ruling is as follows: Issue: A statement of the issue in question. Facts: The facts on which the revenue ruling is based. Law and analysis: The IRS’s application of current law to the issue in the revenue ruling. Holding: How the IRS will treat the transaction. 3. Identify the three types of Treasury regulations. Distinguish them and describe the weight each carries in a tax researcher’s analysis. 1) Proposed regulation: Before and during the hearings process, a Notice of Proposed Rulemaking is referred to as a proposed regulation, it does not have the effect of law. Proposed regulations are useful for understanding the IRS’s current position on an issue but generally should not be relied on by a taxpayer unless the IRS provides explicit advice on doing so.
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  • Spring '14
  • JeffreyJ.Bryant

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