What are temporary regulations? What weight do they carry in the tax researcher’s analysis?
Answer to relevant QuestionsThe 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? Explain each of the elements of this citation: Rev. Rul. 2013-5, 2013-9 I. R. B. 525. Discuss the precedential value of private letter rulings, determination letters, and technical advice memoranda. What role do these items play in conducting tax research? Define the terms regulation and Treasury decision. Where are TDs published so that interested parties can comment on them? What is an IRS announcement? When is it used? In your opinion, could a tax practitioner rely on an IRS announcement as authority for a tax return position?
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