C239 EXAMINATION QUESTIONS AND VERIFIED
ANSWERS
Tax Law Sources - Statutory
Administrative
Judicial Decisions
Secondary Decisions
What are Statutory Sources? - Statutory:
-US Constitution
-IRC Reports
-Congressional Committee Reports
What are IRC Reports? - Internal Revenue Code, Title 26 of the CFR
What are Administrative Sources? - Administrative:
-Treasury Regulations
-Revenue Rulings
-Revenue Procedures
-PLRs
-TAMs
What are the 2 main characteristics of Treasury Regulations? - 1. Legislative Regulations
---Legislation directed by legislators
2. Interpretive Regulations
---Interprets the IRC
What are the 3 characteristics of Regulations? - 1. Proposed
-No authority over taxpayers
, 2. Temporary
-Does have authority, not as much as Final Regs.
3. Final
-Has the most authority over taxpayers
What are Revenue Rulings? - They address the application of the IRS rules to specific fact
situations.
Revenue Procedures - Explain in greater detail IRS practices and procedures in administering the
tax law.
Private Letter Rulings (PLRs) - Addresses an individual taxpayers specific tax situation. This
becomes the only authority for that taxpayer.
Technical Advice Memorandum (TAMs) - Issued by the IRS to address a specific situation
What are Judicial Decisions? - Judicial Decisions:
What are Secondary Decisions? - Secondary Decisions:
-DNA
-RA
-CCH
-Newspaper articles
-Journal articles
-Law review articles
Helpful to start and develop research. But no authority before the IRS.
What are the primary sources of tax law? - Statutory
Administrative
Judicial Decisions
Starting at the top, what are the three levels of the courts? - 1. Supreme Court
2. U.S. Circuit Courts of Appeals
3. U.S. District Courts
ANSWERS
Tax Law Sources - Statutory
Administrative
Judicial Decisions
Secondary Decisions
What are Statutory Sources? - Statutory:
-US Constitution
-IRC Reports
-Congressional Committee Reports
What are IRC Reports? - Internal Revenue Code, Title 26 of the CFR
What are Administrative Sources? - Administrative:
-Treasury Regulations
-Revenue Rulings
-Revenue Procedures
-PLRs
-TAMs
What are the 2 main characteristics of Treasury Regulations? - 1. Legislative Regulations
---Legislation directed by legislators
2. Interpretive Regulations
---Interprets the IRC
What are the 3 characteristics of Regulations? - 1. Proposed
-No authority over taxpayers
, 2. Temporary
-Does have authority, not as much as Final Regs.
3. Final
-Has the most authority over taxpayers
What are Revenue Rulings? - They address the application of the IRS rules to specific fact
situations.
Revenue Procedures - Explain in greater detail IRS practices and procedures in administering the
tax law.
Private Letter Rulings (PLRs) - Addresses an individual taxpayers specific tax situation. This
becomes the only authority for that taxpayer.
Technical Advice Memorandum (TAMs) - Issued by the IRS to address a specific situation
What are Judicial Decisions? - Judicial Decisions:
What are Secondary Decisions? - Secondary Decisions:
-DNA
-RA
-CCH
-Newspaper articles
-Journal articles
-Law review articles
Helpful to start and develop research. But no authority before the IRS.
What are the primary sources of tax law? - Statutory
Administrative
Judicial Decisions
Starting at the top, what are the three levels of the courts? - 1. Supreme Court
2. U.S. Circuit Courts of Appeals
3. U.S. District Courts
