Assume that the taxpayer has a tax issue in which the only authorities on point are the following: (a) an article written by a famous tax lawyer that supports taxpayer’s position and (b) a Revenue Ruling that does not support taxpayer’s position. What does the researcher advise the taxpayer?
Answer to relevant QuestionsAssume that your best friend has a full scholarship offer for playing football at the University of Colorado at Boulder. The scholarship covers tuition, dorm room, and meal costs at the university. Write a brief memo ...Which of the following tax sources are primary authorities?a. Tax servicesb. Tax Court memorandum decisionsc. Revenue Proceduresd. IRS publicationse. Temporary Treasury RegulationsWhat is the penalty provided under Code Section 6662(b)(2)? Where in that Code section is that penalty defined? Explain the definition in your own words.Diagram the court hierarchy, showing the three courts of original jurisdiction on the bottom, two courts in the middle, and the U.S. Supreme Court on top.Explain the AICPA’s Conceptual Framework that is incorporated into the Code of Conduct.
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