Chapter 2Statutory Sources (slide 1 of 3)Statutory Sources (slide 2 of 3)Statutory Sources (slide 3 of 3)Administrative SourcesRegulations (slide 1 of 4)Regulations (slide 2 of 4)Regulations (slide 3 of 4)Regulations (slide 4 of 4)Revenue Rulings (slide 1 of 2)Revenue Rulings (slide 2 of 2)Revenue Procedures (slide 1 of 2)Revenue Procedures (slide 2 of 2)Other Administrative Pronouncements (slide 1 of 3)Other Administrative Pronouncements (slide 2 of 3)Other Administrative Pronouncements (slide 3 of 3)Federal Judicial SystemJudicial Sources (slide 1 of 2)Judicial Sources (slide 2 of 2)Appeals ProcessCourts’ Weights As PrecedentsTax Court Decisions (slide 1 of 2)Tax Court Decisions (slide 2 of 2)Trial and Appellate Court DecisionsSupreme Court DecisionsTax Research ProcessTax ResearchAssessing The Validity Of Tax Law Sources (slide 1 of 4)Assessing The Validity Of Tax Law Sources (slide 2 of 4)Assessing The Validity Of Tax Law Sources (slide 3 of 4)Assessing The Validity Of Tax Law Sources (slide 4 of 4)Tax PlanningElectronic Tax ResearchTax Research MemoChapter 2Chapter 2Working with the Tax LawWorking with the Tax LawCopyright ©2004 South-Western/Thomson LearningCopyright ©2004 South-Western/Thomson LearningCopyright ©2004 South-Western/Thomson LearningCopyright ©2004 South-Western/Thomson LearningEugene Willis, William H. Hoffman, Jr.,Eugene Willis, William H. Hoffman, Jr.,David M. Maloney and William A. RaabeDavid M. Maloney and William A. RaabeEugene Willis, William H. Hoffman, Jr.,Eugene Willis, William H. Hoffman, Jr.,David M. Maloney and William A. RaabeDavid M. Maloney and William A. RaabeC28 - 2Statutory Sources (slide 1 of 3)Statutory Sources (slide 1 of 3)•Internal Revenue Code–Codification of the Federal tax law provisions in a logical sequence–Have had three codes:•1939, 1954, 1986 •Internal Revenue Code–Codification of the Federal tax law provisions in a logical sequence–Have had three codes:•1939, 1954, 1986C28 - 3Statutory Sources (slide 2 of 3)Statutory Sources (slide 2 of 3)•Example of Code Citation: § 2(a)(1)(A)2 = section number (a) = subsection (1) = paragraph designation (A) = subparagraph designation•Example of Code Citation: § 2(a)(1)(A)2 = section number (a) = subsection (1) = paragraph designation (A) = subparagraph designationC28 - 4Statutory Sources (slide 3 of 3)Statutory Sources (slide 3 of 3)C28 - 5Administrative SourcesAdministrative Sources•Treasury Department Regulations, •Revenue Rulings, •Revenue Procedures, and•Various other administrative pronouncements•Treasury Department Regulations, •Revenue Rulings, •Revenue Procedures, and•Various other administrative pronouncementsC28 - 6Regulations (slide 1 of 4)Regulations (slide 1 of 4)–Issued by U.S. Treasury Department–Provide general interpretations and guidance in applying the Code–Issued by U.S. Treasury Department–Provide general interpretations and guidance in applying the CodeC28 - 7Regulations (slide 2 of 4)Regulations (slide 2 of 4)•Issued as:–Proposed: preview of final regulations•Do not have force and effect of law–Temporary: issued when guidance needed quickly•Same authoritative value as final regulations–Final:•Force and effect of law•Issued as:–Proposed: preview of final regulations•Do not have force and effect of law–Temporary: issued when guidance needed quickly•Same authoritative value as final regulations–Final:•Force and effect of lawC28 - 8Regulations (slide 3 of 4)Regulations (slide 3 of 4)•Example of Regulation citation: Reg. § 1.117-4(c)(1) 1 = income tax regulation 117 = code section to which regulation pertains -4 = fourth regulation on section 117 issued•Example of Regulation citation: Reg. § 1.117-4(c)(1) 1 = income tax regulation 117 = code section to which regulation pertains -4 = fourth regulation on section 117 issuedC28 - 9Regulations (slide 4 of 4)Regulations (slide 4 of 4)•Example of Proposed Regulation citation: Prop. Reg. § 1.2•Example of Temporary Regulation citation: Temp. Reg. § 1.1(i)-1T•Example of Proposed Regulation citation: Prop. Reg. § 1.2•Example of Temporary Regulation citation: Temp. Reg. § 1.1(i)-1TC28 - 10Revenue Rulings (slide 1 of 2)Revenue Rulings (slide 1 of 2)•Officially issued by National Office of IRS–Provide specific interpretations and guidance in applying the Code–Less legal force than Regulations–Issued in IRB and accumulated in the Cumulative Bulletins•Private Letter Rulings are rulings issued to a specific taxpayer •Officially issued by National Office of IRS–Provide specific interpretations and guidance in applying the Code–Less legal force than Regulations–Issued in IRB and accumulated in the Cumulative Bulletins•Private Letter Rulings are rulings issued to a specific taxpayerC28 - 11Revenue Rulings (slide 2 of 2)Revenue Rulings (slide 2 of 2)•Example of Temporary Revenue Ruling citation–Rev. Rul. 2002-4 I.R.B. No. 4, 389•Rev. Ruling No. 4, on pg. 389 of 4th weekly issue of Internal Revenue Bulletin for 2002 •Example of Permanent Revenue Ruling citation–Rev. Rul. 2002-4, 2002-1 C.B. 389•Rev. Ruling No. 4 on pg. 389 of Vol. 1 of the Cumulative Bulletin for 2002•Example of Letter Ruling citation–Ltr. Rul. 200231006•6th ruling issued in the 31st week of 2002•Example of Temporary Revenue Ruling citation–Rev. Rul. 2002-4 I.R.B. No. 4, 389•Rev. Ruling No. 4, on pg. 389 of 4th weekly issue of Internal Revenue Bulletin for 2002 •Example of Permanent Revenue Ruling citation–Rev. Rul. 2002-4, 2002-1 C.B. 389•Rev. Ruling No. 4 on pg. 389 of Vol. 1 of the Cumulative Bulletin for 2002•Example of Letter Ruling citation–Ltr. Rul. 200231006•6th ruling issued in the 31st week of 2002C28 - 12Revenue Procedures (slide 1 of 2)Revenue Procedures (slide 1 of 2)•Concerned with the internal procedures of IRS–Issued similar to Revenue Rulings–Issued in IRB and accumulated in the Cumulative Bulletins•Concerned with the internal procedures of IRS–Issued similar to Revenue Rulings–Issued in IRB and accumulated in the Cumulative BulletinsC28 - 13Revenue Procedures (slide 2 of 2)Revenue Procedures (slide 2 of 2)•Example of Revenue Procedure citation–Rev. Proc. 92-29, 1992-1 CB 748•29th Rev. Procedure in 1992 found in volume 1 of Cumulative Bulletin on page 748•Example of Revenue Procedure citation–Rev. Proc. 92-29, 1992-1 CB 748•29th Rev. Procedure in