Instructions
Provide complete written (typed) responses to the following:
1) What department and agency of the U.S. government have the responsibility to administer the federal tax laws?
2) Define the terms regulation and Treasury Decision. Where are TDs published so that interested parties can comment on them?
3) Define and distinguish between general (interpretive) and legislative regulations.
4) What are temporary regulations? what weight do they carry in the tax researcher’s analysis?
5) What is a revenue ruling?
6) Describe the structure of a typical revenue ruling.
7) What resources are available to help the tax researcher who wishes to check the status of a revenue ruling?
8) Of what relevance to the tax practitioner is a revenue procedure?
9) Which office of the IRS issues PLRs? Who may request such a ruling? what kinds of issues are addressed therein?
10) Sometimes a PLR is generalized and included in an official IRS publication. What form does this recast private ruling take?
11) What is a determination letter? Which office of the IRS issues determination letters? What kinds of issues are addressed therein?
12) What is a TAM? Who may request it? What kinds of issues are addressed there? Does the IRS include TAM in any official publication?
13) Discuss the precedential value of PLRs, determination letters, and TAM. What role do these items play in conducting tax research?
14) One of the most important IRS publication is the IRB. How often is this document published? Name six items that typically are published in the IRB.
15) In what publication(s) would a tax researcher find the official listing of the IRS acquiescences and nonacquiescences to a TAx Court decision?
16) Can the IRS change its position on acquiescences or nonacquiescences?
17) Must the IRS acquiescences or nonacquiescences to every issue in a court decision?
18) What is an IRS announcement? When is it used? In your opinion, could a tax practitioner rely on an IRS announcement as authority for a tax return position?
19) What is an IRS notice? When is it used? In your opinion, could a tax practitioner rely on an IRS notice as authority for a tax return position?
