Using RiA's Checkpoint to Find Primary Sources of Tax Authority(1)

Using RiA's Checkpoint to Find Primary Sources of Tax Authority(1)

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Using RIA’s Checkpoint to Find Sources of Tax Authority How would you use RIA to locate the following five sources of tax authority. a. Reg §1.721-1(a) b. Rev. Rul. 60-314, 1960-2 C.B. 48 c. Rev. Proc. 86-46, 1986-2 C.B. 739 d. Rev. . Rul. 98-36, I.R.B. No. 31,6 e. IRC §351 Each of these five citations (a through e) are primary authorities (sometimes referred to as primary sources) of the tax law. A primary authority is an original pronouncement that comes from statutory , administrative or judicial sources . A primary source is a more powerful source of authority than a secondary one. A secondary source or secondary authority consists, as our textbook indicates “mainly of books, periodicals, articles, newsletters and editorial judgments in tax services such as CCH and RIA.” A statutory authority of the tax law includes the U.S. Constitution, tax treaties (often negotiated between counrties in regards to how individuals in each country will be subject to tax) and the Internal Revenue Code. An administrative source of the tax law includes the various pronouncements of the U.S. Treasury Department and the Internal Revenue Service (IRS). The IRS promulgates rules interpreting the Internal Revenue Code. It does this through its issuance of Regulations, Revenue Rulings, Revenue Procedures and other Announcements. A
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Using RiA's Checkpoint to Find Primary Sources of Tax Authority(1)

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