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Chapter2_3of3 - Chapter 2(Part 3 of 3 Tax Practice and...

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1 Chapter 2 (Part 3 of 3) Tax Practice and Research
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2 ADMINISTRATIVE PRONOUNCEMENTS
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3 Below is Sec. 509(a) from the Infernal enue Code. SEC. 509. PRIVATE FOUNDATION DEFINED. (a) GENERAL RULE.-- For purposes of this title, the term "private foundation" means a domestic or foreign organization described in section 501(c)(3) other than— (1) an organization described in section 170(b)(1)(A) (other than in clauses (vii) and (viii)); (2) an organization which… (3) an organization which— (A) is organized, and at all times thereafter is operated, exclusively for the benefit of, to perform the functions of, or to carry out the purposes of one or more specified organizations described in paragraph (1) or (2), (B) is operated, supervised, or controlled by or in connection with one or more organizations, described in paragraph (1) or (2), and (C) is not controlled directly or indirectly by one or more disqualified persons (as defined in section 4946 ) other than foundation managers and other than one or more organizations described in paragraph (1) or (2); and (4) an organization which is organized and operated exclusively for testing for public safety. For purposes of paragraph (3), an organization described in paragraph (2) shall be deemed to include an organization described in section 501(c)(4) , (5) , or (6) which would be described in paragraph (2) if it were an organization described in section 501(c)(3) For $1,000,000, For $1,000,000, what does this mean? what does this mean? Welcome to Assignment 7
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4 Sometimes the law is just not clear and requires some interpretation! Where can we get some guidance? Should we ask Moe or Larry?
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5 For $50, who interprets the law? The EXECUTIVE BRANCH (i.e., the Treasury Department including the IRS) and the JUDICIAL BRANCH (i.e., the Courts)
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6 PRIMARY AUTHORITIES Administrative Interpretations What building is this? The Treasury Department, home of the IRS!
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7 What does the law mean? Interpretations are provided by the Treasury and its most famous branch, the IRS. Types of administrative interpretations include: Treasury Regulations Revenue Rulings Revenue Procedures Technical Advice Memoranda Other types of administrative interpretations Administrative Interpretations
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8 Interpreting the Law Primary Sources Judicial * Tax Court *District Court *Claims Court *Appeals Court * Supreme Court Administrative *Regulations *Revenue Rulings *Revenue Procedures *Letter Rulings *Announcements/Notices *AODs, GCMs, and others Interpretations Internal Revenue Code The government’s interpretations. Can you explain them?
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9 Regulations: final, proposed, temporary Revenue Rulings Private Letter Rulings Revenue Procedures Technical Advice Memorandum Notices Actions on Decisions Determination Letter General Counsel Memorandum
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10 Believe It or not, the Code may be unintelligible . Check Ripley’s!
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