Working with the Tax Law - Ch02

Working with the Tax Law - Ch02 - CHAPTER 2 WORKING WITH...

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CHAPTER 2 WORKING WITH THE TAX LAW SOLUTIONS TO PROBLEM MATERIALS Status: Q/P Question/ Present in Prior Problem Topic Edition Edition 1 Code Unchanged 1 2 Treaties Unchanged 2 3 Code New 4 Regulations, revenue rulings, revenue procedures, Unchanged 4 letter rulings 5 Authority Unchanged 5 6 Regulations Unchanged 6 7 Citations Modified 7 8 Small Cases Division Unchanged 8 9 U.S. District Court Modified 9 10 Judicial alternatives: trial courts Unchanged 10 11 Judicial system Unchanged 11 12 Tax Court and appeal process Modified 12 13 Trial Courts Unchanged 13 14 Circuit Court of Appeals New 15 Supreme Court Unchanged 15 16 Court decision validity Unchanged 16 17 Tax Court Regular and Memorandum decisions Unchanged 17 18 Citations Unchanged 18 19 Abbreviations Unchanged 19 20 Commerce Clearing House Unchanged 20 21 Court of Federal Claims Unchanged 21 22 Cumulative Bulletin Unchanged 22 23 Citations Unchanged 23 24 Issue recognition Unchanged 24 25 Judicial system Unchanged 25 26 Judicial system Unchanged 26 27 Citations Unchanged 27 2-1
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2-2 2003 Entities Volume/Solutions Manual Status: Q/P Question/ Present in Prior Problem Topic Edition Edition 28 Tax sources Modified 28 29 Ethics problems Unchanged 29 30 Ethics problems Unchanged 30 31 Internet New 32 Uncertainty produced by court decisions Unchanged 32 33 Code citations Unchanged 33 Bridge Discipline Problem 1 Sources of federal tax law Unchanged 1 Research Problem 1 Code Unchanged 1 2Citations Unchanged 2 3 Citations Unchanged 3 4 Citations Unchanged 4 5 Citations Unchanged 5 6 Reliability Unchanged 6 7 Terminology New 8 Locating Federal Register New 9 Internet activity Unchanged 9 10 Internet activity Unchanged 10 11 Internet activity Unchanged 11 PROBLEM MATERIAL 1. With some exceptions, much of the 1939 Code was incorporated into the 1954 Code and the 1954 Code into the 1986 Code. This point is important when one assesses judicial decisions that interpret provisions of the 1939 and 1954 Codes. If the same provision was included in the Internal Revenue Code of 1986 and has not been subsequently amended, the decision is likely to have continuing validity. p. 2-3 2. Smith, Raabe, and Maloney, CPAs 5191 Natorp Boulevard Mason, OH 45040 March 22, 2002 Mrs. Barbara Brown Mallard, Inc. 100 International Drive Tampa, Florida 33620 Dear Mrs. Brown:
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Working With The Tax Law 2-3 This letter is in response to your request about information concerning a conflict between a U.S. treaty with the Ukraine and a Section of the Internal Revenue Code. The major reason for treaties between the U.S. and certain foreign countries is to eliminate double taxation and to render mutual assistance in tax enforcement. Section 7852(d) provides that if a U.S. treaty is in conflict with a provision in the Code, neither will take general precedence. Rather, the more recent of the two will have precedence. In your case, the Ukrainian treaty takes precedence over the Code section. A taxpayer must disclose on the tax return any positions where a treaty overrides a tax
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Working with the Tax Law - Ch02 - CHAPTER 2 WORKING WITH...

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