What are temporary regulations? What weight do they carry in the tax researcher’s analysis?
> Name the four court case reporters that publish Supreme Court decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.
> Differentiate between the Supreme Court’s overturning of a lower court’s decision and its denial of a writ of certiorari.
> How does one petition the Supreme Court to hear one’s tax case?
> Name the three court case reporters that publish court of appeals decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.
> Are the U.S. courts of appeals national courts? What type of cases do they hear?
> Name the three court case reporters that publish U.S. Court of Federal Claims decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.
> Is the U.S. Court of Federal Claims a national court? Must a taxpayer go to Washington, D.C. to present a case to this court?
> The rules that govern practice before the IRS are found in Circular 230. Discuss what entails practice before the IRS and state which section of Circular 230 contains the definition.
> Locate the most recent committee reports associated with each of the following code sections (if any) using a tax service such as Checkpoint. Give the citation to the committee report, the Public Law number, and a brief explanation of how the Public Law
> Name the three court case reporters that publish tax and nontax district court decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.
> Is a federal district court a national court? How many judges hear a case brought before a federal district court?
> Specific items of tax authority have different “values” in helping the tax researcher to solve his or her problem. Explain this statement and describe how it applies to the tax research process.
> Which of the trial courts would best serve a taxpayer litigating an issue of a technical tax nature? Why?
> Tax Court memorandum decisions are not published by the federal government. However, commercial reporters include these decisions. Illustrate the elements of both a temporary and a permanent citation for a Tax Court memorandum decision, using both the CC
> Where are regular Tax Court decisions published? Illustrate the elements of both a temporary and a permanent regular Tax Court citation. Explain what each part of the citation means.
> What is the small tax case procedure of the U.S. Tax Court? What is the maximum amount of the deficiency that can be the subject of a small tax case hearing? Comment on the trial procedures in small tax cases.
> Explain each of the elements of this citation: Rev. Proc. 2013-14, 2013-3 I.R.B. 283.
> Explain each of the elements of this citation: Rev. Rul. 96-41, 1996-2 C.B. 8.
> Use an online tax service (e.g., Checkpoint, LexisNexis, CCH IntelliConnect) to locate the following code sections. What other code sections reference each of the sections you found? State which online tax service you used to complete this assignment. a.
> Explain each of the elements of this citation: Rev. Rul. 2013-5, 2013-9 I.R.B. 525.
> Locate the committee reports associated with each of the following code sections using a tax service such as Checkpoint. Give the public law (P.L.) number of the most recent committee report and a brief explanation of how the new provision changes the co
> Answer the following questions about this citation: Reg. § 1.274-6T(a)(2). a. What does the “1” stand for? b. What does the “274” stand for? c. What does the “6T” stand for? d. What does the “(a)” stand for? e. What does the “(2)” stand for?
> Are homeowners who claim an itemized deduction for interest paid on adjustable rate mortgages and then receive refunds in a later year required to show the refunds as taxable income? Database to search: Announcements Keywords: adjustable, rate, mortgage,
> Can proceeds from a life insurance policy be included in a decedent’s gross estate if the policy was purchased by an S corporation for an employee-shareholder? Databases to search: IRC and IRS letter rulings Keywords: Sec. 2042, life, insurance, estate,
> Regular full-time employees are allowed to represent certain organizations before the IRS without being a Circular 230 practitioner. Name the organizations that can be represented by full-time employees, and cite where you found that authority in Circula
> A member of a tax-exempt business league makes deposits into a strike fund. The contribution reverts to the taxpayer if the fund is terminated. Are these deposits tax deductible? Database to search: IRS Technical Advice Memoranda Keywords: business, leag
> What is the current status of each of the following IRS pronouncements? a. Notice 2015-79 b. Revenue Ruling 2004-28 c. Revenue Procedure 93-15 d. Announcement 2014-24
> What is the current status of each of the following IRS pronouncements? a. Notice 2010-92 b. Revenue Ruling 2000-41 c. Revenue Procedure 89-31 d. Announcement 99-110
> Locate the pronouncement at 2004-10 I.R.B. 550. a. What is the number assigned to this written determination? b. What is the subject matter discussed in this written determination?
> List the first three section numbers and titles of each of the following subchapters of Chapter 1 of the Internal Revenue Code: a. Subchapter B b. Subchapter E c. Subchapter J d. Subchapter S
> Locate the pronouncement at 2000-2 C.B. 333. a. What is the number assigned to this written determination? b. What is the subject matter discussed in this written determination?
> Locate the pronouncement at 1989-1 C.B. 76. a. What is the number assigned to this written determination? b. What issue(s) does this written determination address? c. What is the holding in this written determination?
> Use an online site to determine what is contained in each of the following. State where you found this information. a. U.S. Const. Art. I, § 9 cl. 3 b. U.S. Const. Art. I, § 8 cl. 1 c. U.S. Const. Art. II, § 2 cl. 2
> What is the current status of each of the following revenue rulings? a. Rev. Rul. 2002-80 b. Rev. Rul. 2001-31 c. Rev. Rul. 98-13
> What is the current status of each of the following revenue rulings? a. Rev. Rul. 2014-27 b. Rev. Rul. 90-65 c. Rev. Rul. 87-34
> For each of the following code sections, how many Treasury regulations have been issued? Give the total number of such regulations and the number of the last regulation. a. § 25A b. § 119 c. § 180 d. § 305
> What is the subject matter of each of the following technical advice memoranda? a. TAM 201445010 b. TAM 200849015 c. TAM 7953001
> Leigh, who is not a Circular 230 practitioner, is employed by Rose, a CPA. One of Rose’s clients has been notified that the IRS has selected his 2015 income tax return for audit. Rose had prepared the return and signed it as preparer. Rose has been calle
> What is the subject of each of the following IRS notices? a. Notice 2012-35 b. Notice 2007-91 c. Notice 95-50
> What is the subject of each of the following revenue rulings? a. Rev. Rul. 2015-20 b. Rev. Rul. 2014-32 c. Rev. Rul. 77-438 d. Rev. Rul. 2005-52
> When was each of the following 1986 code sections originally enacted? State how you obtained this information. a. § 843 b. § 131 c. § 469 d. § 263A
> Briefly describe the subject of each of the following letter rulings. State the type [private letter ruling (PLR), field service advice (FSA), service center advice (SCA), etc.] of each letter ruling. a. 200250019 b. 200130045 c. 201449010 d. 200849015
> Explain each of the elements of this citation: Rev. Proc. 2000-41, 2000-2 C.B. 317.
> Which office of the IRS issues private letter rulings? Who may request such a ruling? What kinds of issues are addressed therein?
> Enumerate the code sections that contain the chief tax law provisions on the following topics: a. S corporations b. Personal holding company tax c. Gift tax d. Tax accounting methods
> Of what relevance to the tax practitioner is a revenue procedure?
> Describe the structure of a typical revenue ruling.
> What is a revenue ruling?
> The burden of proof is on the taxpayer to prove that a provision of the regulations is improper. How could this affect one’s tax research?
> In addition to committee reports, which are byproducts to the development of tax legislation, what other report may be of value to the tax researcher analyzing a new provision of the tax law? Why?
> What is the purpose of each of the following? a. Chief counsel notices (CCN) b. Service center advice (SCA) c. Chief counsel advice (CCA)
> Does the United States have an income tax treaty with any of the following countries? If it does, in what year was the treaty signed? State where you found this information. a. Australia b. Iceland c. Jamaica d. Sri Lanka
> Does the United States have an income tax treaty with any of the following countries? If it does, in what year was the treaty signed? State where you found this information. a. Japan b. United Kingdom c. Egypt d. Germany
> Comment on the statement, “All tax questions can be answered using the Internal Revenue Code.”
> One important problem that faces a tax researcher is interpretation of the Internal Revenue Code. Comment on each of the following interpretation problems: a. Exceptions to a code section b. Words that connect phrases, such as and and or c. Recent change
> Use an online tax service (e.g., Checkpoint, LexisNexis, CCH IntelliConnect) to answer the following questions: a. What is the general content of Internal Revenue Code § 25A? b. What is the general content of Internal Revenue Code § 67? c. What is the ge
> Use an online tax service (e.g., Checkpoint, LexisNexis, CCH IntelliConnect) to answer the following questions: a. What is the general content of Internal Revenue Code § 117? b. What is the general content of Internal Revenue Code § 165? c. What is the g
> Tax protesters who file “frivolous” tax returns or bring “frivolous” proceedings before the U.S. Tax Court are subject to certain fines or other penalties. What are the grounds for imposing each penalty? What is the maximum amount of each penalty?
> What are some of the potential pitfalls in the first step of the tax research process?
> The 16th Amendment to the Constitution had a significant effect on the U.S. income tax. What was it?
> Discuss the effect of Pollock v. Farmers’ Loan & Trust Co. on the development of U.S. income tax laws.
> What is the purpose of each of the following? a. Technical memorandum (TM) b. General counsel memorandum (GCM) c. Action on decision (AOD)
> The tax researcher must be careful not to overlook connecting words such as and, or, at least, and more than. Explain why this is important.
> Are there any exceptions to the general formatting rules for a code section? Give examples.
> Discuss the evolution of today’s Internal Revenue Code.
> What is a public law number? In P.L. 100-203, what do the “100” and the “203” indicate?
> When are committee reports useful to a tax researcher?
> Briefly summarize the usual steps of the legislative process for the development of federal tax legislation.
> When an Internal Revenue Code section and a tax treaty provision appear to conflict, which usually prevails?
> What is a tax treaty? Explain the purpose of a tax treaty. What matters generally are covered in a tax treaty?
> In order for them to have limited practice rights, the IRS requires non-credentialed tax return preparers to participate in the IRS Annual Filing Season Program. What does participation require, and why do you think the IRS has made this change?
> Discuss the powers of taxation that are granted to Congress by the U.S. Constitution. Are any limits placed on the powers of Congress to so tax?
> In what publication(s) would a tax researcher find the official listing of the IRS acquiescences and nonacquiescences to a Tax Court decision?
> In the current year, Dave receives stock worth $125,000 from his employer. The stock is restricted and cannot be sold by Dave for seven years. Dave estimates the stock will be worth $300,000 after the seven years. List as many tax research issues as you
> Many states have an ethics education requirement to become a CPA. Determine each of the following state’s ethics education requirements to become a CPA: a. California b. Texas c. North Carolina d. Your home state
> John and Marsha are married and filed a joint return for the past year. During that year, Marsha was employed as an assistant cashier at a local bank and, as such, was able to embezzle $75,000, none of which was reported on their joint return. Before the
> Joey parked his car on the top of a hill when he went to watch the X Games in San Diego. He did not properly set his brakes or curb the wheels when he parked the car. When he returned from the games, he found his car had rolled down the hill, smashed int
> Answer each of the following questions: a. What is found in Subpart C, § 10.51 of Circular 230? b. In Circular 230, where are the rules on knowledge of client omissions found? c. Describe the requirements of § 1.400.200 of the AICPA Code of Conduct. d. W
> Answer each of the following questions: a. What is found in Subpart A, § 10.7(a) of Circular 230? b. Describe the requirements of § 1.520.001 of the AICPA Code of Conduct. c. Which SSTS discusses whether a member may rely without verification on informat
> Jennifer owns 200 acres of land on which she grows flowers to sell to local nurseries. Her adjusted basis in the land is $30,000. She receives condemnation proceeds of $20,000 from the state for 10 acres of her land on which a new freeway will be built.
> Determine if your campus has any of the following online tax research services available for student use. If a service is available on your campus, describe how you would gain access to that system for research projects in your tax classes. a. LexisAdvan
> Which of the selected tax journals listed in Exhibit 2-5 can be found online? Which are available through your university’s library in either electronic or hard copy?
> In the tax research process, the researcher has an obligation to the client to evaluate authority. Do the precedents in all tax authority carry the same value? Explain.
> Discuss the difference between a revenue ruling and a revenue procedure.
> Phred Phortunate won his state lotto two years ago. His lotto ticket was worth $10 million, which was payable in 20 annual installments of $500,000 each. Phred paid $1 for the winning ticket. The lotto in Phred’s state does not allow winners to receive t
> Dr. Diego Dissolution is recently divorced and has some questions regarding payments he is making to his ex-wife (Mrs. D.). Diego is 45 years old and has a successful dental practice. Mrs. D. was divorced from her first husband six years ago. Diego is pa
> Tom and Donna were divorced three years ago. At the time of their divorce, they owned a residence whose value had significantly increased during the marriage. Tom remained half-owner of the house, but he moved out and allowed Donna to continue living in
> Which of the following situations would most likely result in a violation of the practitioner’s ethical standards? Explain your answer. a. A CPA (not in public practice) is controller of a bank and grants permission to the bank to use his “CPA” title in
> Juanita Sharp purchased a large parcel of property for $120,000. A short time after purchasing the property, Sharp submitted plans for the division of the parcel into six lots and the construction of three single-family residences on three of the lots. T
> Matthew Broadway was a partner in the law firm of Johnson & Smith, a partnership of 20 partners, for the past 10 years. Without the knowledge or consent of the other partners, Matthew worked on a highly complicated acquisition and merger project for six
> Sam Manuel has been employed on a full-time basis as an electrical engineer for the past three years. Prior to obtaining full-time employment, he was self-employed as an inventor of complex electronic components. During this period of self-employment, mo
> Which of the following is a contingent fee under Circular 230 § 10.27? A fee (1) that is based on a percentage of the refund reported on a return, (2) that is based on a percentage of the taxes saved, or (3) that otherwise depends on the specific result
> On December 1, 2014, Ericka receives $18,000 for three months’ rent (December 2014, January 2015, and February 2015) for an office building. List as many tax research issues as you can to determine the tax consequences of this transaction. Do not attempt
> The Mucho Oro Indian Tribe operates a casino on its reservation in Arizona. The casino is very profitable, and therefore the tribe has excess money to invest. The tribe is approached by an entrepreneur who wants to build an outlet mall next to the casino
> Distinguish between a citation with “I.R.B.” in it and one with “C.B.” in it.
> Tax law provisions tend to change over time. Explain how this might affect tax research and planning.
> What is the precedent-setting value of each of the following cases? a. Lowell Bar Association v. Loeb b. Bercu c. Sperry v. Florida
> Summarize what is discussed in each of the following SSTS: a. SSTS No. 1 b. SSTS No. 4 c. SSTS No. 6
> Ned Naive operated several franchised stores, and at the home office’s suggestion, he consolidated its payroll and accounting functions with Andy the Accountant. Andy is not a CPA. Last year, Andy began misappropriating taxpayers’ escrowed tax withholdin
> Vincent (“Vinny”) Vineyard is a very successful physician in Temecula, California. He earns approximately $800,000 per year from his medical practice. His two children have graduated from college, and he and his wife are now “empty-nesters.” His son, Vin
