SOUTH-WESTERN FEDERAL TAXATION
2024 COMPREHENSIVE VOLUME 47TH
EDITION YOUNG PERSELLIN NELLEN
MALONEY CUCCIA LASSAR CRIPE
SOLUTION MANUAL CERTIFICATION
REVIEW SET 2026 ANSWERS GUARANTEED
PASS
⫸ Circuit Court of Appeals Answer: Any of 13 Federal courts that
consider tax matters appealed from the U.S. Tax Court, a U.S. District
Court, or the U.S. Court of Federal Claims. Appeal from a U.S. Court of
Appeals is to the U.S. Supreme Court by Certiorari.
⫸ Citator Answer: A tax research resource that presents the judicial
history of a court case and traces the subsequent references to the case.
When these references include the citating cases' evaluations of the cited
case's precedents, the research can obtain some measure of the efficacy
and reliability of the original holding.
⫸ Court of original jurisdiction Answer: The Federal courts are divided
into courts of original jurisdiction and appellate courts. A dispute
between a taxpayer and the IRS is first considered by a court of original
jurisdiction (i.e., a trial court). The four Federal courts of original
jurisdiction are the U.S. Tax Court, the U.S. District Court, the Court of
Federal Claims, and the Small Cases Division of the U.S. Tax Court.
, ⫸ Determination letter Answer: Upon the request of a taxpayer, the IRS
will comment on the tax status of a completed transaction.
Determination letters frequently are used to determine whether a
retirement or profit sharing plan qualifies under the Code, and to
determine the tax-exempt status of certain nonprofit organizations.
⫸ Federal District Court Answer: A trial court for purposes of litigating
Federal tax matters. It is the only trial court in which a jury trial can be
obtained.
⫸ Finalized Regulation Answer: The U.S. Treasury Department
Regulations (abbreviated Reg.) represent the position of the IRS as to
how the Internal Revenue Code is to be interpreted. Their purpose is to
provide taxpayers and IRS personnel with rules of general and specific
application to the various provisions of the tax law. Regulations are
published in the Federal Register and in all tax services.
⫸ Interpretive Regulation Answer: A Regulation issued by the Treasury
Department that purports to explain the meaning of a particular Code
Section. An interpretive Regulation is given less deference than a
legislative Regulation.
⫸ Legislative Regulation Answer: Some Code Sections give the
Secretary of the Treasury or his delegate the authority to prescribe
Regulations to carry out the details of administration or to otherwise
complete the operating rules. Regulations issued pursuant to this type of
2024 COMPREHENSIVE VOLUME 47TH
EDITION YOUNG PERSELLIN NELLEN
MALONEY CUCCIA LASSAR CRIPE
SOLUTION MANUAL CERTIFICATION
REVIEW SET 2026 ANSWERS GUARANTEED
PASS
⫸ Circuit Court of Appeals Answer: Any of 13 Federal courts that
consider tax matters appealed from the U.S. Tax Court, a U.S. District
Court, or the U.S. Court of Federal Claims. Appeal from a U.S. Court of
Appeals is to the U.S. Supreme Court by Certiorari.
⫸ Citator Answer: A tax research resource that presents the judicial
history of a court case and traces the subsequent references to the case.
When these references include the citating cases' evaluations of the cited
case's precedents, the research can obtain some measure of the efficacy
and reliability of the original holding.
⫸ Court of original jurisdiction Answer: The Federal courts are divided
into courts of original jurisdiction and appellate courts. A dispute
between a taxpayer and the IRS is first considered by a court of original
jurisdiction (i.e., a trial court). The four Federal courts of original
jurisdiction are the U.S. Tax Court, the U.S. District Court, the Court of
Federal Claims, and the Small Cases Division of the U.S. Tax Court.
, ⫸ Determination letter Answer: Upon the request of a taxpayer, the IRS
will comment on the tax status of a completed transaction.
Determination letters frequently are used to determine whether a
retirement or profit sharing plan qualifies under the Code, and to
determine the tax-exempt status of certain nonprofit organizations.
⫸ Federal District Court Answer: A trial court for purposes of litigating
Federal tax matters. It is the only trial court in which a jury trial can be
obtained.
⫸ Finalized Regulation Answer: The U.S. Treasury Department
Regulations (abbreviated Reg.) represent the position of the IRS as to
how the Internal Revenue Code is to be interpreted. Their purpose is to
provide taxpayers and IRS personnel with rules of general and specific
application to the various provisions of the tax law. Regulations are
published in the Federal Register and in all tax services.
⫸ Interpretive Regulation Answer: A Regulation issued by the Treasury
Department that purports to explain the meaning of a particular Code
Section. An interpretive Regulation is given less deference than a
legislative Regulation.
⫸ Legislative Regulation Answer: Some Code Sections give the
Secretary of the Treasury or his delegate the authority to prescribe
Regulations to carry out the details of administration or to otherwise
complete the operating rules. Regulations issued pursuant to this type of
