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What is the purpose of Tax Research?
Tax Research is conducted to determine the tax consequences of specific transactions to specific taxpayers.
What are the steps in Tax Research?
- Determine the facts
- Identify issues
- Locate applicable authorities
- Evaluate authorities
- Analyze facts in light of authorities
- Communicate results and recommendations
What are the Primary Sources of Tax Law?
- Treasury Regulations
- Judicial interpretations
- Other administrative sources
What are Treasury Department Regulations?
Authority granted by Congress to interpret the Code.
What are Proposed Regulations?
- Represent the Treasury Department's official interpretation of the Code.
- Not as authoritative.
What are Temporary Regulations?
- Usually issued immediately after passage of a major tax act to provide guidance to taxpayers.
- Less authoritative than final regulations but they are still binding on taxpayers.
What are Final Regulations?
They are issued as Treasury decisions.
What are Interpretive Regulations?
They are issued under general authority of Sec. 7805.
What are Legislative Regulations?
Congress delegates its rule-making authority to the Treasury Department.
What is a Letter Ruling?
A taxpayer writes and asks the IRS to explain the tax consequences of a particular transaction.
What is a Technical Advice Memorandum?
Request by an IRS agent for technical assistance.
What is a Treasury Decision?
- Regulations or announcement of the IRS' position on a court decision.
- Published in the IRB.