The burden of proof is on the taxpayer to prove that a provision of the regulations is improper. How could this affect one’s tax research?
Answer to relevant QuestionsWhat is a revenue ruling? Explain each of the elements of this citation: Rev. Rul. 96-41, 1996-2 C. B. 8. Which IRS documents are open to public inspection under I. R. C. § 6110? Discuss the difference between a revenue ruling and a revenue procedure. What is an IRS notice? When is it used? In your opinion, could a tax practitioner rely on an IRS notice as authority for a tax return position?
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