Pg 714 what is the difference between primary

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[Pg. 714] What is the difference between primary authority and secondary authority?
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Primary vs. Secondary Authority. Solution: Primary authority comes directly from statutory, administrative or judicial sources. Secondary authority consists of tax services, books, journals, and newsletters that assist the taxpayer in locating and interpreting primary authorities .
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Which of the following sources is not considered to be primary authority? [Pg. 714] a. Internal Revenue Code b. Regulations c. Court Cases d. Tax journal articles
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Which of the following sources is not considered to be primary authority? [Pg. 714] a. Internal Revenue Code b. Regulations c. Court Cases d. Tax journal articles
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Tax Research 729 Compliance vs Tax Planning 729 1: Establish Facts and Issues 730 2: Locate Relevant Authorities 730 3: Importance of Authorities 731 4: Reach Conclusions 732 Recommendations Communicate Results
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Facts 735 Issues 736 Conclusions 737 Reasoning 738 Research Memorandum
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Types of Research Tax Compliance Research Facts are known [transaction is completed] Goal is to determine the consequence of a completed transaction Tax Planning Research Facts are open-ended [can plan the transaction] Goal is to structure a future transaction for taxpayer’s advantage Non-tax factors must be considered
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Tax Research Process Determine the facts and establish relevance Determine the issue(s) Locate and evaluate the relevant authorities Assess the importance of each Understand the hierarchy of weight Reach a conclusion and communicate the results
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Code Code Subject Code Code Subject Start Stop Subtitle A - Income Taxes Start Stop Subtitle A - Income Taxes- Cont'd Chapter 1. Normal Taxes and Surtaxes 1361 1379 A1S Subchapter S - S Corporations 1 59 A A1A Subchapter A. Determination of Tax Liability 1381 1388 A1T Subchapter T. Cooperatives 1 5 Individual tax rates 1391 1399 A1U Subchapter U. Empowerment zones, etc. 11 15 Corporate tax Rates, Changes in rates A1V Subchapter V. Title 11 Cases 21 26 Non-Refundable Personal Tax Credits A1W Subchapter W. District of Columbia Enterprize Zone 27 36 Other Credits 1400 A 1400 L Increase in Sec. 179 write-off 38 45 F Business Related Credits 1401 1403 A2 Chapter 2. Taxes on Self Employment: Def., Tax Rates, etc. 46 53 Investment Credit, Work Opportunity Credit, AMT Credit 1441 1446 A3 Chapter 3. Aliens 55 59 A Alternative minimum tax and environmental tax 1461 1464 A3 Withholding Tax (Also, Chapters 4 & 5 have been repealed) 61 149 A1B Subchapter B. Computation of Taxable Income 1501 1563 A6 Chapter 6. Consolidated Returns, Controlled Groups, etc. 61 68 Gross income defined - Also AGI and other overall rules 2001 2704 B11 Subtitle B - Estate and Gift Taxes (Chapters 11-14) 71 90 Items specifically included in gross income 2001 2058 Estate Tax 101 140 Items specifically excluded from gross income 2101 2210 Sections for non citizens, etc.
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  • Fall '08
  • BURTON
  • Taxation in the United States, Tax Court, Court District Court Appeals Court Supreme Court

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