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Legal authority and tax research

SEE 3 Chapter 15 · IRS outline 2E1, 2E2, 2E3, 2E4, 2E5, 2E6, 2E7, 2E8, 2F6

Walt's examiner says his deduction is 'not allowed under IRS policy'. Walt's nephew found a blog that says it is. Nadia needs to know which voices actually count: the Code, the regulations, rulings, court cases, the IRS's own manual, a publication, a treaty. This chapter ranks the sources of tax law, explains what each one binds, and shows Theo how to build an argument that will hold up in an exam, at Appeals or in court.

In this chapter

1. The Code at the top
2. Treasury regulations
3. Revenue rulings, revenue procedures and the IRB
4. Written determinations: PLRs, TAMs and determination letters
5. The IRM, publications and forms: helpful, not authority
6. Courts, precedent and tax treaties

This chapter has 6 lessons and 50 practice MCQs with explanations, plus flashcards and a recall sheet.

What this chapter covers

• The Code and regulations
• revenue rulings and procedures
• case law
• forms and publications
• private letter rulings
• the IRM
• treaties
• authority that counts
• avoidance and evasion

Chapter 14: The taxpayer's finances and ability to pay · Chapter 16: Statutes of limitations and deadlines