Persuasive Committee Reports useful for determining Congressional intent when

Persuasive committee reports useful for determining

This preview shows page 10 - 15 out of 32 pages.

Persuasive Committee Reports (useful for determining Congressional intent when Code and Regs. are unclear) Cumulative Bulletins [CB] ( U.S. Government.). Internal Revenue Bulletin [IRB] if written within 6 months House Ways and Means Committee Senate Finance Committee Joint Conference Committee (no legal effect; only guidance) Bluebook (interprets new legislation) Bluebook (a government-issued, blue- covered book) Joint Committee on Taxation (no legal effect; only guidance) Chapter 2, Exhibit 4c Research Sources for Legislative Authority
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CCH Federal Taxation Comprehensive Topics 11 of 32 Authoritative Documents Research Sources Authorship Binding Persuasive Final Regulations (Treasury Decisions) Federal register (U.S. Government.) Tax services (CCH, RIA and West). U.S. Treasury Department Temporary Regulations (issued without opportunity for public comment because timing is critical) Federal Register (U.S. Government) Cumulative Bulletin (U.S. Government) Tax services (CCH, RIA, and West). U.S. Treasury Department (binding if < 3 years old) (nonbinding if over 3 years old) Proposed Regulations Federal Register (U.S. Government) Cumulative Bulletin (U.S. Government) Tax services (CCH, RIA, and West). U.S. Treasury Department (nonbinding preview of final Regs.) Research Sources for Administrative Authority Chapter 2, Exhibit 5a
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CCH Federal Taxation Comprehensive Topics 12 of 32 Authoritative Documents Research Sources Authorship Binding Persuasive Revenue Rulings (interprets tax laws) Cumulative Bulletins (U.S. Government) National office of IRS (not approved by the Treasury) Revenue Procedures (addresses internal procedures of IRS) Cumulative Bulletins (U.S. Government) National office of IRS (not approved by the Treasury) Letter Rulings (explains how IRS will treat a proposed transaction for tax purposes; issued to taxpayers) IRS Letters Rulings Reports (CCH) Private Letter Rulings (RIA) Daily Tax Reports (BNA) Tax Analysts & Advocates, TAX NOTES National office of IRS (only precedent value is for the taxpayer addressed in letter) Chapter 2, Exhibit 5b Research Sources for Administrative Authority
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CCH Federal Taxation Comprehensive Topics 13 of 32 Authoritative Documents Research Sources Authorship Binding Persuasive Technical Advice Memoranda [TAMs] (addresses how IRS will treat a completed transaction for tax purposes; issued to District Office, hence “memorandum”) IRS Position Reporter (CCH) Tax Notes (Tax Analysts) Internal Memoranda of the IRS (RIA) National office of IRS (only precedent value is for the taxpayer addressed in memo) Determination Letters (mainly deal with pension plans and tax- exempt organizations) Not published, but available by IRS for public inspection District Director of IRS (only precedent value is for the taxpayer addressed in letter) Chapter 2, Exhibit 5c Research Sources for Administrative Authority
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CCH Federal Taxation Comprehensive Topics 14 of 32 Research Sources for Judicial Authority Authority Research Source Binding Persuasive U.S. Supreme Court (4 of 9 justices needed to
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