Answering clients’ tax questions accurately and on time is a key challenge for tax practitioners. Through simple, plain language explanations and examples, this course will help practitioners perform tax research more efficiently by describing the structure of the primary sources, highlighting the differences between primary and secondary sources, and detailing the steps in the tax research process.
Learning Objectives
- Describe the different levels of authority in tax law
- Differentiate between the different types of administrative authority in tax law
- Identify the different courts that hear cases involving tax law
- Illustrate the organization of the Internal Revenue Code, the Treasury Regulations, and Revenue Rulings
- Identify the circumstances when a client may want to consider requesting a private letter ruling
- Differentiate between primary and secondary pieces of authority
- Illustrate the steps to the tax research process and the parts of a tax research memorandum
Major Topics
- Tax code hierarchy
- Organization of an Internal Revenue Code section
- Special rules for IRC citation
- Citing other primary authority
- Private letter rulings
- Primary vs. secondary authority
- Secondary sources of authority
- Steps in the tax research process
- Research memoranda
