Citations to primary authorities references made to a

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Citations to Primary Authorities References made to a primary authority should include a full citation Examples are Internal Revenue Code: Sec. 108 Treasury Regulation: Reg. Sec. 1.61-12 Revenue Ruling: Rev. Rul. 54-56, 1954-2 C.B. 108 U.S. Tax Court Case: Julian S.
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Regulation Citations -1. In the citation Reg. §1.247-3, what do the 1 and the 247 indicate?
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Regulation Citations - 2. Solution: The 1 is a prefix that refers to an income tax regulation; the 247 is a root number that designates the Code section to which the regulation is related.
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1. Which of the following statements about regulations is not true? a. They are issued by the Treasury Department. b. Proposed regulations have more authority than temporary regulations. c. Final regulations are issued as Treasury Decisions. d. Legislative regulations have more authority than interpretative regulations. e. A regulation’s identifying number includes the code section which it interprets.
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1. Which of the following statements about regulations is not true ? a. They are issued by the Treasury Department. b. Proposed regulations have more authority than temporary regulations. c. Final regulations are issued as Treasury Decisions. d. Legislative regulations have more authority than interpretative regulations. e. A regulation’s identifying number includes the code section which it interprets.
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Legislative Executive Judicial Congress President Courts Internal Treasury Court Revenue Regulations Cases Code Revenue Rulings Trial Court Committee Revenue Procedures Appeals Reports Notices Court Announcements Supreme Letter Rulings, etc. Court Federal Government Treaties
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1 Internal Revenue Code For Each Type 2 Committee Reports 1 What is the source? 3 Regulations 2 What is process by which 4 Revenue Rulings this type of law is written? 5 Revenue Procedures 3 Where do I find the law? 6 Other Admin. Law 4 When and Why would 7 Tax Court- Regular I want to use this law? 8 Tax Court- Memo 5 What characteristics 9 Tax Court- Summary affect the way I use it? 10 Claims Court Is it brief or detailed, etc.? 11 District Court 6 How reliable is this 12 Appeals Court source of law? 13 Supreme Court 7 How is it cited? Sources of Tax Law & Major Questions
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Tax Services 727 Computer-Assisted Research 727 Citators 729 Tax Periodicals 729 Secondary Sources
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Secondary Authorities: Tax Services Tax services fall into two categories Services with limited editorial discussion but many short interpretive comments CCH’s Standard Federal Tax Reporter RIA’s United States Tax Reporter Services with extensive editorial discussion and interpretation of the law
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Secondary Authorities: Others Computer assistance tools are used to speed research LEXIS & WESTLAW Internet access CD-ROM Citators are used to determine the history of a judicial decision Tax Periodicals are used to keep up with current developments
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Primary vs. Secondary Authority.
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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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