Second Deck

Question 1

What are the three parts of tax law?

Answer 1

IRC- letter of the law

Tax regs/Treasury Regs/Treasury Decision- help interpret and apply the IRC

Case law and court decisions- the biggest part of the three

Question 2

What are the steps for creating a regulation to implement tax law?

Answer 2

Notice of Proposed Rulemaking (NPRM)- presents proposed regulations

Public comments- either written or via a hearing

Input is taken into account to create the final step: a Treasury Decision published in the Federal Register

Question 3

Where are revenue rulings published?

Answer 3

In the Internal Revenue Bulletin

Question 4

What’s a private letter ruling?

Answer 4

PLR

When a taxpayer with a complicated situation asks for the IRS to review it and tell him what to do

Only applies to that taxpayer at that particular time, so it doesn’t become part of case law

Question 5

Where can a taxpayer go when they disagree with the determination of the IRS?

Answer 5

US Tax Court

Question 6

What are the categories of decision that the US Tax Court offers?

Answer 6

Summary -
less than $50k
no appeals or precedent

Regular -
new or unusual points of law
panel of judges
Pub. in US Tax Court Reports

Memorandum -
clarify settled law as it applies to specific facts
Pub. in Tax Court Memorandum Decisions