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Tax 2012 Ch. 5

Principles of Taxation for Business and Investment Planning, Ch. 5

What are the two types of tax research? 1) Compliance and 2) Planning
___ __________ is the process by which the tax consequences of a completed or proposed transaction are determined. Tax research
What are the six steps to tax research? GILARD Get the facts, Identify the issues, Locate relevant authority, Analyze authority, Repeat, Document your research
What are the two classes of tax authority? 1) Primary and 2) Secondary
What are the three branches of primary authority? Legislative, Executive/Administrative, and Judicial
Any publication created by the government could be considered ________ authority. primary
The three branches of government are: 1) Legislative (Congress), 2) Executive/Administrative (President and agencies), and 3) Judicial (court system).
Congress is responsible for __________ laws. creating
True or False? The constitution always has the ultimate authority. True
What amendment deals with taxes in the U.S. Constitution? The sixteenth (16th)
The constitution is a _______ authority and part of the __________ branch. primary, legislative
“The Code” refers to the Internal Revenue Code of ___________. 1986
The Code uses ___________ language and is written with a legislative __________. statutory , intent
True or False? The U.S. legislative branch has created tax treaties with other countries. True
The primary authority legislative branch uses two main sources for tax authority: The U.S. constitution and __________. the internal revenue code
Title ______ of the United States Code talks about taxes. 26
What are the steps for a bill to become law? 1) Start at House Ways and Means Committee 2) Full House of Representatives 3) Senate-Finance Committee 4) Senate Votes 5) Bill goes to Joint Conf. Committee 6) Back to vote for both 7) President vetoes or signs
Treasury regulations help to ________ the law. interpret
The IRS is under the authority of the _____ ____ _________. department of treasury
Treasury regulations are (interpretive/legislative). interpretive
What are the three types of treasury regulations? Proposed, temporary, and final.
Treasury Regulations share almost equal authority with ____________. the I.R. Code
Revenue Rulings and Procedures are the highest authority created by the __________ ________ ___________. internal revenue service
Revenue rulings tell you how you should (solve a problem/file your taxes). solve a problem
Procedures created by the IRS tell you when to file a 1040. True or False? True.
Private Letter Rulings are used for low risk audits. True or False? False. PLR are used for high risk audits.
Private Letter Rulings are binding to the IRS for every U.S. citizen. True or False? False. PLR are only binding to the individual that wrote in.
Private Letter Rulings are not available to the public. True or False? False. PLR are public records.
Technical Advice Memorandas are usually requested by a (CPA/IRS) auditor. IRS
If you have a dispute with the IRS. What type of court will your case start in? A trial court: U.S. Tax Court, U.S. District Court, or U.S. Court of Federal Claims.
After a trial court, you can send your case to an ___________ court. Appellate
If the U.S. Supreme Court chooses not to view your case then the U.S. Courts of Appeals decision is final. True or False? True
True or False? It is OK to cite secondary authorities in a tax research paper. False
Textbooks, professional journals, and commercial tax services are all examples of _______ authorities. secondary
What feature is used to check the validity of judicial authorities or IRS rulings? the Citator
You should (always/never) cite a secondary source? never
Created by: 835093078