CHAPTER 2
WORKING WITH THE TAX LAW
LECTURE NOTES
TAX SOURCES
STATUTORY SOURCES OF THE TAX LAW
1.
2.
Relationship Between the Constitution and the Sixteenth Amendment.
a.
Constitution. The source of the Federal taxing authority is the U.S. Constitution:
“The Congress shall have Power to lay and collect Taxes, Duties, Imposts and
Excises, to pay the Debts and provide for the common Defense and general
Welfare of the United States; but all Duties, Imposts and Excises shall be uniform
throughout the United States.” (Art. I, § 8, Cl. 1)
b.
Sixteenth Amendment. The Sixteenth Amendment is the foundation of our
Federal income tax: “The Congress shall have power to lay and collect taxes on
incomes, from whatever source derived, without apportionment among the several
States, and without regard to any census or enumeration.”
Origin of the Internal Revenue Code.
a.
Prior to 1939 Federal tax law was comprised only of the various revenue acts
passed by Congress. This unwieldy accumulation of laws was inconvenient and
confusing for both enforcement and compliance.
b.
The Internal Revenue Code of 1939.
c.
(1).
In 1939 Congress codified the tax laws. Codification consists of
organizing the provisions of the tax laws in a logical sequence and placing
them in a separate part of the Federal Statutes.
(2).
The Internal Revenue Code is now Title 26 of the U.S. Code.
(3).
This codification is known as the Internal Revenue Code of 1939.
The Internal Revenue Code of 1954.
2-1
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2-2
d.
e.
(1).
Because of additional tax legislation since 1939, Congress reorganized and
renumbered the Internal Revenue Code again in 1954.
(2).
This recodification is known as the Internal Revenue Code of 1954.
The Internal Revenue Code of 1986.
(1).
The Tax Reform Act of 1986 made substantial changes to the Internal
Revenue Code.
(2).
While the Code was not renumbered as it was in 1954, it is, nonetheless,
referred to as the Internal Revenue Code of 1986 because of the sweeping
changes made.
Now statutory amendments to the tax law are integrated into the Internal Revenue
Code of 1986 (e.g. the Economic Stimulus Act of 2008, the American Recovery
and Reinvestment Tax Act of 2009, the Patient Protection and Affordable Care
Act of 2010, and the Health Care and Education Reconciliation Act of 2010.
THE LEGISLATIVE PROCESS
3.
a.
Origin of a tax bill. Tax legislation normally originates in the House Ways and
Means Committee of the House of Representatives. A tax bill might originate in
the Senate when it is attached to other legislative proposals.
(1)
The Tax Equity and Fiscal Responsibility Act of 1982 originated in the
Senate, and its constitutionality was unsuccessfully challenged in the
courts.
(2)
The Senate version of the Deficit Reduction Act of 1984 was attached as
an amendment to the Federal Boat Safety Act.
b.
If acceptable to the committee, the proposed legislation is referred to the entire
House of Representatives.
c.
Approved bills are then sent to the Senate Finance Committee.
d.
Bills are then referred to the entire Senate.
e.
Approved bills are referred to the President who may either approve the bill (in
which case it becomes law) of veto the bill.
f.
A vetoed bill may still be overridden.
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Working with the Tax Law
2-3
g.
When the House and the Senate disagree on the provisions of a bill, it is referred
to a joint committee in an attempt to resolve the differences.
h.
Committee Reports.
(1)
Referrals from the House Ways and Means Committee, the Senate
Finance Committee, and the Conference Committee usually are
accompanied by Committee Reports.
(2)
These reports explain the provisions of the proposed legislation. They are
important, therefore, in subsequently interpreting the tax law. They are
said to reveal Congressional intent.
ARRANGEMENT OF THE CODE
4.
The Internal Revenue Code is Title 26 of the U.S. Code.
a.
It arranged by Subtitle, Chapter, Subchapter, Parts, and Sections.
b.
However, the Internal Revenue Code (IRC) is primarily referenced by section
number. For example, IRC section 61 defines gross income. The symbol “§” is
generally used rather than the word “section,” e.g. IRC § 62(a) Gross Income
Defined.
c.
Citing the Code on page 2-6 illustrates how specific parts of the code section are
referenced.
EFFECT OF TREATIES
5.
Tax Treaties. In addition to the Internal Revenue Code, the United States often signs
bilateral tax treaties with other countries.
a.
The provisions of these treaties are not integrated into the Internal Revenue Code.
However, the IRS as well as some tax publishing services provide this
information.
b.
When the Internal Revenue Code and treaties conflict, the most recent provision
takes precedent.
c.
With certain exceptions, a taxpayer must disclose on the tax return any filing
position for which a treaty overrides a tax law. There is a $1,000 per failure to
disclose penalty for individuals and a $10,000 per failure to disclose penalty for C
corporations
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ADMINISTRATIVE SOURCES OF THE TAX LAW (see Exhibit 2.1 on page 2-7 in the
text)
6.
Treasury Department Regulations. The Treasury Department under § 7805(a) has a duty
to issue rules and regulations to explain and interpret the Code.
a.
Treasury Decisions. Final Regulations are issued as Treasury Decisions (TD’s) in
the Federal Register. Regulations carry considerable authority as the official
interpretation of tax statutes. They are arranged in the same sequence as the
Internal Revenue Code and have the force and effect of law.
b.
Organization. Treasury Regulations are arranged in the same order as the Code.
c.
d.
7.
(1)
An additional number is added, however, as a prefix to indicate what type of tax
the regulation is interpreting (e.g. 1 for income tax, 20, for estate tax, 31 for
employment tax).
(2)
The Code section being interpreted is provided next.
(3)
The numbering convention after the coded section is in chronological order and
has no relation the Code subsections. (See text page 2-8 for an illustration.)
Types of regulations issued.
(1)
Legislative Regulations.
(2)
Interpretative Regulations.
(3)
Procedural Regulations.
(4)
Temporary Regulations – may be cited as precedent and are found in the
Federal Register, Internal Revenue Bulletin, and Cumulative Bulletin.
They are issued as Proposed Regulations and automatically expire within
three years after the date of issuance.
Validity of a Regulation. One way courts assess the validity of a Regulation is by
the legislative re-enactment doctrine. Here a Regulation is considered to have
received Congressional approval if the regulation was finalized many years earlier
and during the interim period Congress has not amended the relevant statutory
language.
Revenue Rulings and Revenue Procedures. These are official pronouncements of the
National Office of the IRS.
a.
Revenue Rulings are official pronouncements of the National Office of the IRS
and provide guidance to both IRS personnel and taxpayers in handling routine tax
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Working with the Tax Law
2-5
matters. They usually deal with more restricted problems than Regulations and
do not carry the same legal force and effect.
b.
8.
9.
Letter Rulings and Determination Letters. Letter rulings and determination letters have
in common the fact that they apply only to the person who requested the ruling or letter.
a.
Letter ruling. A letter ruling is a statement issued by the National Office of the
IRS in response to a taxpayer’s request, which applies the tax law to a proposed
transaction. Revenue rulings often results from a specific taxpayer’s request for a
letter ruling. Like letter rulings, determination letters are issued at the request of
taxpayers and provide guidance on the application of the tax law. They differ
from letter rulings in that the issuing source is an IRS executive rather than the
National Office of the IRS, and involve completed transactions. Determination
letters are not published.
b.
Determination letter. A determination letter is a statement issued by the Area
Director in response to a taxpayer, which applies the tax law to a completed
transaction.
Technical Memoranda and Technical Advice Memoranda. These sources are not the
same.
a.
Technical Memoranda (TMs) are memoranda from the IRS Commissioner to the
Assistant Secretary of the Treasury for Tax Policy. They are drafted by the
Legislation and Regulation Division of the Office of Chief Counsel and relate to
proposed Treasury Decisions or Regulations.
b.
10.
Revenue Procedures are issued in the same manner as Revenue Rulings, but they
deal with the internal management practices and procedures of the IRS and do not
carry the same legal force and effect.
Technical Advice Memoranda (TAMs) are furnished by the National Office of the
IRS upon request of an Area Director or an Appeals Officer of the IRS in
response to any technical or procedural question (e.g., a completed transaction).
Other Administrative Pronouncements.
a.
Announcements of Proposed Regulations as well as the related public hearings.
b.
Treasury Decisions.
c.
Executive orders.
d.
Tax conventions (i.e., international treaties).
e.
Legislation (including Committee Reports).
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f.
Certain court decisions may be reproduced.
g.
Announcements of court decisions in which the IRS acquiesces or does not
acquiesce.
h.
Punitive action (e.g., disbarment, suspension) taken against persons (e.g.,
attorneys, CPAs) practicing before the IRS.
ADDITIONAL LECTURE RESOURCE
Provider of the Tax Source
Internal Revenue Code
Regulations
Revenue Ruling
Letter Ruling
Notices and Announcements
Determination Letter
Technical Advice Memorandum
Treasury Decision
Revenue Procedure
General Counsel Memorandum
Action on Decision
Field Service Advice
Technical Expedited Advice Memorandum
Congress/President
U.S. Treasury Department
National Office of IRS
National Office of IRS
National Office of IRS
Area Director of IRS
National Office of IRS
U.S. Treasury Department
National Office of IRS
General Counsel’s Office of IRS
Office of Chief Counsel of IRS
Office of Chief Counsel of IRS
National Office of IRS
JUDICIAL SOURCES OF THE TAX LAW
11.
Precedential Value. American law, following English common law, is frequently “made”
by judicial decisions. Under the doctrine of stare decisis, each decision has precedential
value for future decisions with the same controlling set of facts.
12.
Trial Courts (Courts of Original Jurisdiction). A taxpayer chooses the route to pursue a
tax conflict from among four alternatives (as illustrated in Figure 2.3 on page 2-12 and
Concept Summary 2.1 on page 2-14 in the text).
a.
U.S. Court of Federal Claims (hears tax and other claims against the Federal
government). This court formerly was called the U.S. Claims Court. There is
only one U.S. Court of Federal Claims and meets most often in Washington, D.C.
Decisions are appealed to the U.S. Court of Appeals (Federal Circuit).
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Working with the Tax Law
13.
14.
2-7
b.
U.S. Tax Court (hears only tax cases). Taxpayer does not pay the deficiency
before trial. Decisions are appealed to the U.S. Court of Appeals (Regional
Circuit).
c.
Small Cases Division of the U.S. Tax Court (hears only tax cases). No appeal
available.
d.
U.S. District Courts (hears tax as well as nontax cases). A jury trial is available.
Decisions are appealed to the U.S. Court of Appeals (Regional Circuit). See
Figure 2.4 on page 2-14 in the text.
Small Cases Division. The broken line between the U.S. Tax Court and the Small Cases
Division in Figure 2.3 of the text indicates that there is no appeal from the Small Cases
Division.
a.
$50,000 or less. This court hears cases involving amounts of $50,000 or less.
b.
No written record. The proceedings are informal, and there was no written record
of such cases before 2002. Some of the more recent cases can now be found on
the U.S. Tax Court Internet Website (http://www.ustaxcourt.gov/).
c.
Informal Proceedings.
(1)
No necessity for the taxpayer to be represented by a lawyer or other tax
adviser.
(2)
Special trial judges, rather than Tax Court judges, preside over the
proceedings.
(3)
Decisions are not precedent for any other court and are not reviewable by
any higher court.
Appellate Courts. The two appellate courts are the Circuit Courts of Appeals (11
geographical circuits, the circuit for the District of Columbia, and the Federal Circuit)
and the Supreme Court (see Figure 2.4 in the text).
a.
All courts must follow the decisions of the U.S. Supreme Court.
b.
A particular Court of Appeals need not follow the decisions of another Court of
Appeals.
c.
District Courts, the Tax Court, and the Court of Federal Claims must abide by the
precedents set by the Court of Appeals of jurisdiction.
d.
Appeal to the Supreme Court
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(1)
Appeal to the Supreme Court is not automatic.
(2)
A Writ of Certiorari is a request to appeal a case to the Supreme Court.
(3)
If the Supreme Court agrees to hear a case it will grant the Writ. The Court
rarely hears a tax case.
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ADDITIONAL LECTURE RESOURCE
JURISDICTION OF THE COURTS OF APPEALS
First
Maine Maryland
Massachusetts
New Hampshire
Rhode Island
Puerto Rico
Fourth
Arkansas
North Carolina
South Carolina
Virginia
West Virginia
Second
Connecticut
New York
Vermont
Fifth
Canal Zone
Louisiana
Mississippi
Texas
Third
Delaware
New Jersey
Pennsylvania
Virgin Island
Sixth
Kentucky
Michigan
Ohio
Tennessee
District of Columbia
Washington, D.C.
Eighth
Colorado
Iowa
Minnesota
Missouri
Nebraska
North Dakota
South Dakota
Ninth
Alaska
Arizona
California
Hawaii
Idaho
Montana
Nevada
Oregon
Washington
Guam
Tenth
Kansas
New Mexico
Oklahoma
Utah
Wyoming
Eleventh
Alabama
Florida
Georgia
Federal
U.S. Court of Federal
Claims
Seventh
Illinois
Indiana
Wisconsin
WORKING WITH THE TAX LAW - TAX RESEARCH
15.
16.
Definition of Research. Tax research is the method whereby one determines the best
available solution to a situation that possesses tax consequences.
a.
In other words, it is the process of finding a professional conclusion to a tax
problem.
b.
The problem might originate either from completed or proposed transactions.
Tax Research Procedures. Tax research involves the following procedures:
a.
Identifying and refining the problem.
b.
Locating the appropriate tax law sources.
c.
Assessing the validity of the tax law sources.
d.
Arriving at the solution or at alternative solutions with due consideration given to
nontax factors.
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2-10
e.
f.
Effectively communicating the solution to the taxpayer or the taxpayer’s
representative. See Figure 2.6 and Figure 2.7 on pages 2-27 and 2-28 in the text.
(1)
A clear statement of the issue.
(2)
In more complex situations, a short review of the fact pattern that raises
the issue.
(3)
A review of the pertinent tax law sources (e.g., Code, Regulations,
Revenue Rulings, judicial authority).
(4)
Any assumptions made in arriving at the solution.
(5).
The solution recommended and the logic or reasoning supporting it.
(6)
The references consulted in the research process.
Following up on the solution (where appropriate) in the light of new
developments.
17.
Identifying the Problem. This step consists of gathering all the information about the tax
consequences of an existing or a proposed transaction.
18.
Refining the Problem. This step generally involves analyzing alternative proposals and
the possible tax implications of each option.
LOCATING THE APPROPRIATE TAX LAW SOURCES
19.
20.
Locating the appropriate tax law sources. The next step is to research the tax law to fine
authoritative sources of the tax law that describe or explain the appropriate tax treatment
of various alternative proposals. The major publishers of tax research services are:
a.
Standard Federal Tax Reporter, Commerce Clearing House.
b.
United States Tax Reporter, Research Institute of America.
c.
Federal Tax Coordinator 2d, Research Institute of America.
d.
Tax Management Portfolios, Bureau of National Affairs.
Working with Tax Services. Instruction in using the various tax services is beyond the
scope of this text. However, there are two important observations. First, always check for
the most current developments. Second, always read the pertinent Code sections and
regulations relevant to the question at hand.
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Working with the Tax Law
21.
2-11
Tax Commentary. Various tax publications often discuss topics relevant to the issue
being researched. These article will often cite primary sources, thereby reducing the
research effort.
ASSESSING TAX LAW SOURCES
22.
23.
24.
25.
Interpreting the Internal Revenue Code.
a.
The Internal Revenue Code is the tax law, as passed by Congress.
b.
Because it is law, it is written using rather precise legal terminology that is,
sometimes, difficult to interpret. Further, several Code sections are often
interrelated, further compounding interpretation.
c.
Nonetheless, because it is the governing law, it should be the starting point for
most tax research.
Assessing the Significance of a Treasury Regulation.
a.
Treasury Regulations are the official interpretation of the Code. As such
examining agents (Internal Revenue Agents) must give the Regulations the same
weight as the Code when interpreting tax law.
b.
Taxpayers disagreeing with the interpretation of a Treasury Regulation have the
burden of proof to show that the Regulation is not consistent with the Code and
Committee Reports.
c.
Occasionally Congress will direct the Secretary of the Treasury to prescribe
regulations to administer Code provisions. These so called Legislative
Regulations have the force of law.
Assessing the Significance of Other Administrative Sources of the Tax Law.
a.
Revenue Rulings. Revenue Rulings reflect the IRS interpretation of the tax law in
specific situations. They do not, however, have the force of law and can be
overturned in court.
b.
Actions on Decisions. When the IRS disagrees with a court decision, it may
decide, for a variety of reasons, not to appeal the decision. In such situations, it
will often announce its non acquiescence. Thus, taxpayers being audited for
similar issues will need to litigate in order to prevail.
Assessing the Significance of Judicial Sources of the Tax Law. While court cases have
precedential value, the weight of that value depends on several variables:
 The level of the court
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2013 Annual Edition/Instructor’s Guide with Lecture Notes
2-12




26.
The legal residence of the taxpayer
The type of decision
The weight of the decision
Subsequent events
Assessing the Significance of Other Sources.
a.
Primary Sources. The Constitution, the Internal Revenue Code, Treasury
Regulations, judicial decisions, Committee Reports, tax treaties, and IRS
pronouncements are the primary sources of the tax law.
b.
Secondary Sources. Legal periodicals, treatises, legal opinions, General Counsel
Memoranda, and written determinations are secondary sources.
c.
Substantial Authority. Generally, primary sources are considered authoritative
while secondary sources are not.
(1)
The exception is that, for purposes of the accuracy related penalty, some
secondary sources are considered substantial authority.
(2)
Note, most IRS publications intended to provide helpful individual and
business tax guidance (e.g., pub. 17), are not considered authoritative
sources.
COMMUNICATING TAX RESEARCH
27.
Emphasize the six bullet points in the text about the importance of communicating the
results of tax research.
COMPUTERS AND TAX RESEARCH
28.
Online Commercial Services. There are several online tax research services (see Exhibit
2.2 on page 2-28 in the text). These services generally provide both primary and
secondary sources of the tax law and allow researchers to search, link, store, and export
the results of tax research.
29.
Additional Online Sources. Exhibit 2.3 on page 2-29 in the text lists several web sites that
provide tax information.
a.
The IRS provides all of its forms and publications free on line.
b.
The courts, (including the tax court) also provide free access to opinions.
c.
The Internal Revenue Code and the Treasury Regulations are available free from
several sources including the IRS web site.
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Working with the Tax Law
d.
2-13
Additionally, there are a variety of web sites and blogs that provide free tax
related information and analysis. (Note that quality of these sources may be
difficult to ascertain.
TAX RESEARCH ON THE CPA EXAM
30.
31.
The Uniform CPA Exam. Tax questions on the CPA exam are included in the three-hour
regulation section. In addition to multiple choice questions, there are simulations that
provide some authoritative literature that the candidate must research in completing the
case study.
The AICPA maintains a web site to assist with the Uniform CPA Exam; www.cpaexam.org. The site includes tutorials and sample tests including simulations.
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2-14
2013 Annual Edition/Instructor’s Guide with Lecture Notes
ADDITIONAL LECTURE RESOURCE
Primary and Secondary Tax Sources
Primary
16th Amendment to Constitution
Tax Treaty
Internal Revenue Code Section
U.S. Supreme Court Decision
U.S. Circuit Court of Appeals Decision
Tax Court Memorandum Decision
Tax Court Regular Decision
U.S. District Court Decision
U.S. Court of Federal Claims Decision
Small Cases Division of U.S. Tax Court
Final Regulation
Temporary Regulation
Proposed Regulation
Revenue Ruling
Revenue Procedure
Senate Finance Committee Report
Bluebook
Letter Ruling
Technical Advice Memorandum
Actions on Decisions
Determination Letter
Harvard Law Review article
Field Service Advice
General Counsel Memorandum
Secondary
X
X
X
X
X
X
X
X
X
X
X
X*
X
X
X
X
X
X
X
X
X
X
X
X
* For three years.
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2013 Annual Edition/Instructor’s Guide with Lecture Notes
2-16
Figure 2--2
LOCATION OF JUDICIAL SOURCES
USTC
Series
AFTR
Series
F.Supp.
Series
F.3d
Series
Cls.Ct.
Series
S.Ct.
Series a
U.S. District
Courts
(tax cases)
Yes
Yes
Yes
No
No
No
U.S. Tax
Court b
No c
No c
No
No
No
No
U.S. Court
of Federal
Claims d
(tax cases)
Yes
Yes
No e
Yes e
Yes e
No
U.S. Courts of
Appeal
(tax cases)
Yes
Yes
No
Yes
No
No
U.S. Supreme Ct.
(tax cases)
Yes
Yes
No
No
No
Yes
U.S. District
Courts f
(all cases)
No
No
Yes
No
No
No
U.S. Courts of
Appeal
(all cases)
No
No
No
Yes
No
No
U.S. Supreme
Court
(all cases)
No
No
No
No
No
Yes
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2-17
Notes:
a
Answers also apply to the United States Supreme Court Reports (abbreviated
U.S.) and to the United States Reports, Lawyers Edition (abbreviated L.Ed.).
b
Regular (not Memorandum) decisions are published by the U.S. Government
Printing Office in Tax Court of the United States Reports.
c
Both CCH and RIA (formerly P-H) have separate services for reporting the
decisions (both Regular and Memorandum) of the U.S. Tax Court.
d
All decisions (both tax and non-tax) of the U.S. Court of Federal Claims are
published by the U.S. Government Printing Office in the Claims Court Reporter
Series. From 1960 to October 1, 1982, Court of Claims decisions were published
in the Court of Claims Reporter Series.
e
From 1932 to 1960, the Court of Claims decisions were published in the F.Supp.
Series. Beginning October 1982, the Claims Court decisions are published in the
Claims Court Reporter. Beginning October 30, 1992, the Claims Court
underwent a further name change. The new designation, U.S. Court of Federal
Claims, begins with Volume 27 of the former Cl.Ct. (West citation) now
abbreviated as Fed.Cl.
f
“All cases” has reference to non-tax as well as tax decisions. Thus, it would
include such varied issues as interstate transportation of stolen goods, civil rights
violations, and anti-trust suits.
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NOTES
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