2010 CCH Comp Topics Ch02 - Click to edit Master subtitle...

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Unformatted text preview: Click to edit Master subtitle style CCH Federal Taxation Comprehensive Topics Chapter 2 Tax Research, Practice, and Procedure 2009 CCH. All Rights Reserved. 4025 W. Peterson Ave. Chicago, IL 60646-6085 1 800 248 3248 www.CCHGroup.com CCH Federal Taxation Comprehensive CCH Federal Taxation Comprehensive 22 of 32 Chapter 2 Exhibits 1. Classification of Materials 2. Judicial Authority 3. Five-Step Research Method 4. Research Sources for Legislative Authority 5. Research Sources for Administrative Authority 6. Research Sources for Judicial Authority 7. Commercial Publishers of Comprehensive Services 8. Commercial Publishers of Judicial Decisions 9. Commercial Publishers of Current Developments Chapter 2, Exhibit Contents CCH Federal Taxation Comprehensive CCH Federal Taxation Comprehensive 33 of 32 Chapter 2 Exhibits 10. Organization of the IRS 11. IRS Communications 12. Examination of Returns 13. Appeals Administrative Process 14. Taxpayer Bill of Rights 15. Choice of Tax Forum 16. Penalties Chapter 2, Exhibit Contents CCH Federal Taxation Comprehensive CCH Federal Taxation Comprehensive 44 of 32 Classification of Materials n Primary or authoritative u Internal Revenue Code (statutory authority) u Treasury Regulations (administrative authority) u Internal Revenue Service Rulings (administrative authority) u Judicial Authority n Secondary or reference u Looseleaf tax reference services u Periodicals u Textbooks u Treatises u Published papers from tax institutes u Symposia u Newsletters Chapter 2, Exhibit CCH Federal Taxation Comprehensive CCH Federal Taxation Comprehensive 55 of 32 Judicial Authority The three courts of original jurisdiction are: n U.S. Tax Court n U.S. District Court n U.S. Court of Federal Claims Chapter 2, Exhibit CCH Federal Taxation Comprehensive CCH Federal Taxation Comprehensive 66 of 32 Judicial Authority The appellate courts are: n U.S. Circuit Courts of Appeals n U.S. Court of Appeals for the Federal Circuit n U.S. Supreme Court Chapter 2, Exhibit CCH Federal Taxation Comprehensive CCH Federal Taxation Comprehensive 77 of 32 Five-Step Research Method 1. Gather the facts and identify the tax issues. 2. Locate and study the primary and secondary authorities relevant to the enumerated tax issues. 3. Update and evaluate the weight of the various authorities. 4. Re-examine various facets of the research. 5. Arrive at conclusions; communicate these conclusions to the client. Chapter 2, Exhibit CCH Federal Taxation Comprehensive CCH Federal Taxation Comprehensive 88 of 32 Authoritative Documents Research Source Authorship Binding Persuasive 16th Amendment Constitution Congress l Internal Revenue Code CCH, RIA, and West tax services Congress l Chapter 2, Exhibit Research Sources for Legislative Authority CCH Federal Taxation Comprehensive CCH Federal Taxation Comprehensive 99 of 32 Authoritative Documents Research Source Authorship Binding Persuasive Tax Treaties (to render mutual assistance between the U.S. and foreign countries in...
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This note was uploaded on 11/08/2010 for the course AC 553 AC 553 taught by Professor Perez during the Summer '09 term at Keller Graduate School of Management.

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2010 CCH Comp Topics Ch02 - Click to edit Master subtitle...

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