ACCY 612 - Tax Research Outline Exam Questions
With Complete Answers
Tax Research - ANSWER The process by which the tax consequences of a completed or
proposed transaction are determined
Two classes of authorities - ANSWER Primary and Secondary
Types of primary authorities - ANSWER Legislative, executive/administrative, and
judicial
Types of secondary authorities - ANSWER Tax services, citators, tax research computer
software systems, & tax journals and newsletters
Legislative authorities - ANSWER Constitution, tax treaties, IRC-Statutory language, and
IRC-Legislative intent
Administrative authorities - ANSWER Regulations, revenue rulings, revenue
procedures, acquiescences, letter rulings, Chief Counsel's Memoranda, and other IRS
pronouncements: (Notices, Announcements, Publications, and Tax return instructions)
Types of Treasury Regulations - ANSWER Proposed, temporary, and final
Proposed regulations - ANSWER Not binding on Taxpayers until finalized
Temporary regulations - ANSWER Will expire if not amended or issued as a final
regulation within 3 years.
Revenue rulings - ANSWER Interpretations by the IRS of the Code and regulations as
they apply to specific factual situations. Represent official policy of the IRS and are
, binding on the IRS until they are revoked, amended, or otherwise changed
Revenue procedures - ANSWER Explain internal IRS administrative practices and
procedures.
Acquiescence - ANSWER IRS accepts decision of the court and will follow the holding in
handling cases with similar facts and circumstances.
Private letter ruling (LTR) - ANSWER Response to specific questions rose by Taxpayers
and typically deals with prospective transactions. Not binding to other taxpayers.
Technical Advice Memorandum (TAM) - ANSWER Basically a LTR for a completed
transaction.
Types of Chief Counsel's Memoranda - ANSWER Technical Memoranda (TM)
General Counsel's Memoranda (GCM)
Actions on Decisions (AOD)
Technical Memoranda (TM) - ANSWER Used to explain treasury regulations
General Counsel's Memoranda (GCM) - ANSWER Explain the authority and reasoning
used to prepare revenue rulings, private letter rulings, and technical advice
memoranda.
Actions on Decisions (AOD) - ANSWER Explain whether the Chief Counsel's Office
believes that an adverse court decision should be appealed.
Appellate courts - ANSWER U.S. Courts of Appeals
U.S. Court of Appeals for the Federal Circuit
With Complete Answers
Tax Research - ANSWER The process by which the tax consequences of a completed or
proposed transaction are determined
Two classes of authorities - ANSWER Primary and Secondary
Types of primary authorities - ANSWER Legislative, executive/administrative, and
judicial
Types of secondary authorities - ANSWER Tax services, citators, tax research computer
software systems, & tax journals and newsletters
Legislative authorities - ANSWER Constitution, tax treaties, IRC-Statutory language, and
IRC-Legislative intent
Administrative authorities - ANSWER Regulations, revenue rulings, revenue
procedures, acquiescences, letter rulings, Chief Counsel's Memoranda, and other IRS
pronouncements: (Notices, Announcements, Publications, and Tax return instructions)
Types of Treasury Regulations - ANSWER Proposed, temporary, and final
Proposed regulations - ANSWER Not binding on Taxpayers until finalized
Temporary regulations - ANSWER Will expire if not amended or issued as a final
regulation within 3 years.
Revenue rulings - ANSWER Interpretations by the IRS of the Code and regulations as
they apply to specific factual situations. Represent official policy of the IRS and are
, binding on the IRS until they are revoked, amended, or otherwise changed
Revenue procedures - ANSWER Explain internal IRS administrative practices and
procedures.
Acquiescence - ANSWER IRS accepts decision of the court and will follow the holding in
handling cases with similar facts and circumstances.
Private letter ruling (LTR) - ANSWER Response to specific questions rose by Taxpayers
and typically deals with prospective transactions. Not binding to other taxpayers.
Technical Advice Memorandum (TAM) - ANSWER Basically a LTR for a completed
transaction.
Types of Chief Counsel's Memoranda - ANSWER Technical Memoranda (TM)
General Counsel's Memoranda (GCM)
Actions on Decisions (AOD)
Technical Memoranda (TM) - ANSWER Used to explain treasury regulations
General Counsel's Memoranda (GCM) - ANSWER Explain the authority and reasoning
used to prepare revenue rulings, private letter rulings, and technical advice
memoranda.
Actions on Decisions (AOD) - ANSWER Explain whether the Chief Counsel's Office
believes that an adverse court decision should be appealed.
Appellate courts - ANSWER U.S. Courts of Appeals
U.S. Court of Appeals for the Federal Circuit
