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Assignment5rulings[1].LC

Assignment5rulings[1].LC - Assignment 5 Administrative...

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Assignment 5   Administrative  Pronouncements (File 2 of 2)
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Administrative Pronouncements Remember, regulations aren’t the only form of administrative guidance Administrative interpretations include: Treasury Regulations Revenue Rulings Revenue Procedures Technical Advice Memoranda Other types of administrative interpretations Let’s look at guidance other than regs
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Revenue Rulings View as mini-cases providing an analysis of the law as it applies to a specific fact situation Contrast with regulations that provide general interpretive guidance about a Code provision Rulings are issued by the National Office of the IRS in response to taxpayer inquiries or court decisions, or out of a perceived need for additional guidance Let’s request a ruling .
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Revenue Rulings Standard format: Issue : States the question Facts : Anonymous facts are stated, with no names or dollar amounts (unlike court cases) Law and Analysis : The IRS provides relevant provisions from the Code, regulations, case law, and prior revenue rulings Holding : The IRS states how it will apply the law given the specific set of facts (answer to issue) Effect on Other Documents : Notes impact on any previously issued revenue rulings
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Revenue Rulings To locate a revenue ruling using an electronic reference service , all you need to know is its number : Rev. Rul. 77-343 Rev. Rul. 77-343 Year of Issuance Issuance for that year
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Revenue Rulings: Citation Otherwise, you need the full citation Get the citation right or your reviewer won’t be able to find it! Revenue rulings are first issued in the weekly Internal Revenue Bulletin (I.R.B) The IRB is then bound into the Cumulative Bulletin (C.B.) A correct citation includes both the revenue ruling number and either the I.R.B. or the C.B. volume number and page number
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Internal Revenue Bulletin location Rev. Rul. 99-56, I.R.B. 1999-51, 1 Rev. Rul. 99-56, I.R.B. 1999-51, 1 Page Week Year Internal Revenue Bulletin Issuance for that year Year of Issuance Revenue Rulings: Citation Note: Some sources cite the year and week before I.R.B.
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Cumulative Bulletin location Rev. Rul. 83-183, 1983-2 C.B. 220 Rev. Rul. 83-183, 1983-2 C.B. 220 Page Cumulative Bulletin Year and Volume Issuance for that year Year of Issuance Revenue Rulings: Citation
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Revenue Rulings:  Authority How much value is a ruling that is not issued directly to the taxpayer? Not as authoritative as Treasury regulations The closer the taxpayer’s facts are to the facts in the revenue ruling, the more authoritative it is for that taxpayer If the taxpayer’s facts and issues are substantially the same as those in the revenue ruling, the taxpayer should not take a contrary position or he (she) will risk the imposition of penalties
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Revenue Rulings:  Reliability The government may change its mind, the courts may overturn a ruling, or the law may change.
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