CH2 Brief - 1 9!“ CHAPTER 2 Primary source...

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Unformatted text preview: 1. 9'?!“ CHAPTER 2 Primary source materials (GOVERNMENT speaking) a. Statutory authority i. ii. iii. Internal Revenue Code of 1986 (the bones) (Title 26 of the US. Code) (the “Code”) 1. Includes more than “income” taxes — e. g, other subtitles include estate and gift taxes and employment taxes 2. Most frequent cite is to a “Section” of the Code Congressional Committee Reports: Express congressional intent Blue Books: By the Staff of the Joint Committee on Taxation for major tax acts b. Administrative authority i. ii. iii. Treasury Department Regulations (meat on the bones — help clarify the Code) (can be legislative, interpretive, or procedural) (also, can be proposed, temporary, or final) (regulations are published in the Federal Register and Internal Revenue Bulletin). 1. A Regulation’s number relates back to the Part (before the decimal point) and Section (after the decimal) of the Code it “interprets.” For example, 1. 453- 1 is a Part 1 1ncome tax regulation interpreting Section 453 of the Code (the “- ” indicates that it is the first regulation for Section 453). Revenue Rulings (more meat) (help ensure particular issues are dealt with consistently) and Revenue Procedures (official statements of procedure) 1. Published by the IRS Other administrative announcements where the IRS communicates with taxpayers and its own personnel 1. Private Letter Rulings, Determination Letters, Technical Advice Memoranda 0. Judicial authority — more meat; various Courts (see Exhibit 2 on page 2-9). 2. Secondary Source Material (PRIVATE SECTOR speaking) a. Convenient aids often used by practitioners, including: i. ii. iii. iv. V. Tax services (e g., CCH’s Standard Federal Tax Reporter (by Code Section), BNA’s Tax Management Portfolios (by Topic)) Citators (help evaluate/update case law) Books Tax periodicals (e. g., journals, magazines) Newsletters (mail and email) Don’ t underest1mate the importance of Secondary Source Materials (which are often the best place to begin tax research). These often highlight several key primary sources in one place and jumpstart your analysis. Research Methodology Tax Administration: Organization of the IRS Tax Practice & Procedure: Examinations, Appeals, SOL, Penalties, and Ethics Rules for Practitioners ...
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