Question: Locate the pronouncement at 2004-10 I.

> Read and brief the following cases: a. Rownd, T.C. Memo. 1994-465 b. Arnes, 93-1 USTC ¶50,016.

> If your last name begins with the letters A–L, read and brief the following cases: a. Sorensen, T.C. Memo. 1994-175 b. Keller, 84-1 USTC ¶9194. If your last name begins with the letters M–Z, read and brief the following cases: c. Washington, 77 T.C. 601

> Find the court decision located at 101 AFTR2d 2008-1612. a. Which court heard the case? b. Who was the judge(s)? c. Which tax year(s) is in question and in what year was the case decided? d. Which code section(s) was at issue? e. What was the issue(s) in

> Find the court decision located at 67 AFTR2d 91-718. a. Which court heard the case? b. Who was the judge(s)? c. Which tax year(s) is in question and in what year was the case decided? d. Which code section(s) was at issue? e. What was the issue(s) involv

> Chapters of the Internal Revenue Code are subdivided into subchapters. How are subchapters identified? What is generally contained in a subchapter?

> The final step in the research process typically involves a memorandum to the client file and/or a letter to the client communicating the results of the research. List the items that should be found in the body of both of these documents.

> 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?

> Find the court decision located at 2014-2 USTC ¶50,516. a. Which court heard the case? b. Who was the judge(s)? c. Which tax year(s) is in question and in what year was the case decided? d. Which code section(s) was at issue? e. What was the issue(s) inv

> Find the court decision located at 108 AFTR 2d 2011-5569. a. Which court heard the case? b. Who was the judge(s)? c. Which tax year(s) is in question and in what year was the case decided? d. Which code section(s) was at issue? e. What was the issue(s) i

> Find the court decision located at T.C. Summary Opinion 2015-65. a. Which court heard the case? b. Who was the judge(s)? c. Which tax year(s) is in question and in what year was the case decided? d. Which code section(s) was at issue? e. What was the iss

> Find the court decision located at T.C. Summary Opinion 2013-21. a. Which court heard the case? b. Who was the judge(s)? c. Which tax year(s) is in question and in what year was the case decided? d. Which code section(s) was at issue? e. What was the iss

> The U.S. Tax Court is a national court that hears cases of taxpayers who may appeal to various geographical courts of appeals. How does the Tax Court reconcile the opposite holdings of two or more of these courts of appeals for taxpayers who work or resi

> Distinguish among a regular, memorandum, and summary decision of the Tax Court.

> The U.S. Tax Court is a national court that meets in Washington, D.C. Does this mean that the taxpayer and his or her attorney must travel to Washington to have a case heard?

> How many judges sit on the U.S. Tax Court? What is the length of time of the appointment of each judge?

> The U.S. Tax Court has undergone an evolution since it was founded. What happened to its structure in 1926, 1943, and 1969, respectively?

> Each subtitle of the Internal Revenue Code contains several chapters. How are chapters identified? What generally is included in a chapter of the code?

> 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?

> Who has the burden of proof in most cases involving the tax law? Why?

> Step 5 in the tax research process is concerned with reaching a conclusion or making a recommendation. If one has not found a clear answer to a tax research problem, how is a conclusion or recommendation to be reached?

> Discuss the precedential value of a court of appeals decision. Which court of appeals decisions are most important to a specific taxpayer?

> Name the four court case reporters that publish Supreme Court decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.

> Differentiate between the Supreme Court’s overturning of a lower court’s decision and its denial of a writ of certiorari.

> How does one petition the Supreme Court to hear one’s tax case?

> Name the three court case reporters that publish court of appeals decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.

> Are the U.S. courts of appeals national courts? What type of cases do they hear?

> Name the three court case reporters that publish U.S. Court of Federal Claims decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.

> Is the U.S. Court of Federal Claims a national court? Must a taxpayer go to Washington, D.C. to present a case to this court?

> The rules that govern practice before the IRS are found in Circular 230. Discuss what entails practice before the IRS and state which section of Circular 230 contains the definition.

> Locate the most recent committee reports associated with each of the following code sections (if any) using a tax service such as Checkpoint. Give the citation to the committee report, the Public Law number, and a brief explanation of how the Public Law

> Name the three court case reporters that publish tax and nontax district court decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.

> Is a federal district court a national court? How many judges hear a case brought before a federal district court?

> Specific items of tax authority have different “values” in helping the tax researcher to solve his or her problem. Explain this statement and describe how it applies to the tax research process.

> Which of the trial courts would best serve a taxpayer litigating an issue of a technical tax nature? Why?

> Tax Court memorandum decisions are not published by the federal government. However, commercial reporters include these decisions. Illustrate the elements of both a temporary and a permanent citation for a Tax Court memorandum decision, using both the CC

> Where are regular Tax Court decisions published? Illustrate the elements of both a temporary and a permanent regular Tax Court citation. Explain what each part of the citation means.

> What is the small tax case procedure of the U.S. Tax Court? What is the maximum amount of the deficiency that can be the subject of a small tax case hearing? Comment on the trial procedures in small tax cases.

> Explain each of the elements of this citation: Rev. Proc. 2013-14, 2013-3 I.R.B. 283.

> Explain each of the elements of this citation: Rev. Rul. 96-41, 1996-2 C.B. 8.

> Use an online tax service (e.g., Checkpoint, LexisNexis, CCH IntelliConnect) to locate the following code sections. What other code sections reference each of the sections you found? State which online tax service you used to complete this assignment. a.

> Explain each of the elements of this citation: Rev. Rul. 2013-5, 2013-9 I.R.B. 525.

> Locate the committee reports associated with each of the following code sections using a tax service such as Checkpoint. Give the public law (P.L.) number of the most recent committee report and a brief explanation of how the new provision changes the co

> Answer the following questions about this citation: Reg. § 1.274-6T(a)(2). a. What does the “1” stand for? b. What does the “274” stand for? c. What does the “6T” stand for? d. What does the “(a)” stand for? e. What does the “(2)” stand for?

> Are homeowners who claim an itemized deduction for interest paid on adjustable rate mortgages and then receive refunds in a later year required to show the refunds as taxable income? Database to search: Announcements Keywords: adjustable, rate, mortgage,

> Can proceeds from a life insurance policy be included in a decedent’s gross estate if the policy was purchased by an S corporation for an employee-shareholder? Databases to search: IRC and IRS letter rulings Keywords: Sec. 2042, life, insurance, estate,

> Regular full-time employees are allowed to represent certain organizations before the IRS without being a Circular 230 practitioner. Name the organizations that can be represented by full-time employees, and cite where you found that authority in Circula

> A member of a tax-exempt business league makes deposits into a strike fund. The contribution reverts to the taxpayer if the fund is terminated. Are these deposits tax deductible? Database to search: IRS Technical Advice Memoranda Keywords: business, leag

> What is the current status of each of the following IRS pronouncements? a. Notice 2015-79 b. Revenue Ruling 2004-28 c. Revenue Procedure 93-15 d. Announcement 2014-24

> What is the current status of each of the following IRS pronouncements? a. Notice 2010-92 b. Revenue Ruling 2000-41 c. Revenue Procedure 89-31 d. Announcement 99-110

> List the first three section numbers and titles of each of the following subchapters of Chapter 1 of the Internal Revenue Code: a. Subchapter B b. Subchapter E c. Subchapter J d. Subchapter S

> Locate the pronouncement at 2000-2 C.B. 333. a. What is the number assigned to this written determination? b. What is the subject matter discussed in this written determination?

> Locate the pronouncement at 1989-1 C.B. 76. a. What is the number assigned to this written determination? b. What issue(s) does this written determination address? c. What is the holding in this written determination?

> Use an online site to determine what is contained in each of the following. State where you found this information. a. U.S. Const. Art. I, § 9 cl. 3 b. U.S. Const. Art. I, § 8 cl. 1 c. U.S. Const. Art. II, § 2 cl. 2

> What is the current status of each of the following revenue rulings? a. Rev. Rul. 2002-80 b. Rev. Rul. 2001-31 c. Rev. Rul. 98-13

> What is the current status of each of the following revenue rulings? a. Rev. Rul. 2014-27 b. Rev. Rul. 90-65 c. Rev. Rul. 87-34

> For each of the following code sections, how many Treasury regulations have been issued? Give the total number of such regulations and the number of the last regulation. a. § 25A b. § 119 c. § 180 d. § 305

> What is the subject matter of each of the following technical advice memoranda? a. TAM 201445010 b. TAM 200849015 c. TAM 7953001

> Leigh, who is not a Circular 230 practitioner, is employed by Rose, a CPA. One of Rose’s clients has been notified that the IRS has selected his 2015 income tax return for audit. Rose had prepared the return and signed it as preparer. Rose has been calle

> What is the subject of each of the following IRS notices? a. Notice 2012-35 b. Notice 2007-91 c. Notice 95-50

> What is the subject of each of the following revenue rulings? a. Rev. Rul. 2015-20 b. Rev. Rul. 2014-32 c. Rev. Rul. 77-438 d. Rev. Rul. 2005-52

> When was each of the following 1986 code sections originally enacted? State how you obtained this information. a. § 843 b. § 131 c. § 469 d. § 263A

> Briefly describe the subject of each of the following letter rulings. State the type [private letter ruling (PLR), field service advice (FSA), service center advice (SCA), etc.] of each letter ruling. a. 200250019 b. 200130045 c. 201449010 d. 200849015

> Explain each of the elements of this citation: Rev. Proc. 2000-41, 2000-2 C.B. 317.

> Which office of the IRS issues private letter rulings? Who may request such a ruling? What kinds of issues are addressed therein?

> Enumerate the code sections that contain the chief tax law provisions on the following topics: a. S corporations b. Personal holding company tax c. Gift tax d. Tax accounting methods

> Of what relevance to the tax practitioner is a revenue procedure?

> Describe the structure of a typical revenue ruling.

> What is a revenue ruling?

> 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?

> What are temporary regulations? What weight do they carry in the tax researcher’s analysis?

> In addition to committee reports, which are byproducts to the development of tax legislation, what other report may be of value to the tax researcher analyzing a new provision of the tax law? Why?

> What is the purpose of each of the following? a. Chief counsel notices (CCN) b. Service center advice (SCA) c. Chief counsel advice (CCA)

> Does the United States have an income tax treaty with any of the following countries? If it does, in what year was the treaty signed? State where you found this information. a. Australia b. Iceland c. Jamaica d. Sri Lanka

> Does the United States have an income tax treaty with any of the following countries? If it does, in what year was the treaty signed? State where you found this information. a. Japan b. United Kingdom c. Egypt d. Germany

> Comment on the statement, “All tax questions can be answered using the Internal Revenue Code.”

> One important problem that faces a tax researcher is interpretation of the Internal Revenue Code. Comment on each of the following interpretation problems: a. Exceptions to a code section b. Words that connect phrases, such as and and or c. Recent change

> Use an online tax service (e.g., Checkpoint, LexisNexis, CCH IntelliConnect) to answer the following questions: a. What is the general content of Internal Revenue Code § 25A? b. What is the general content of Internal Revenue Code § 67? c. What is the ge

> Use an online tax service (e.g., Checkpoint, LexisNexis, CCH IntelliConnect) to answer the following questions: a. What is the general content of Internal Revenue Code § 117? b. What is the general content of Internal Revenue Code § 165? c. What is the g

> Tax protesters who file “frivolous” tax returns or bring “frivolous” proceedings before the U.S. Tax Court are subject to certain fines or other penalties. What are the grounds for imposing each penalty? What is the maximum amount of each penalty?

> What are some of the potential pitfalls in the first step of the tax research process?

> The 16th Amendment to the Constitution had a significant effect on the U.S. income tax. What was it?

> Discuss the effect of Pollock v. Farmers’ Loan & Trust Co. on the development of U.S. income tax laws.

> What is the purpose of each of the following? a. Technical memorandum (TM) b. General counsel memorandum (GCM) c. Action on decision (AOD)

> The tax researcher must be careful not to overlook connecting words such as and, or, at least, and more than. Explain why this is important.

> Are there any exceptions to the general formatting rules for a code section? Give examples.

> Discuss the evolution of today’s Internal Revenue Code.

> What is a public law number? In P.L. 100-203, what do the “100” and the “203” indicate?

> When are committee reports useful to a tax researcher?

> Briefly summarize the usual steps of the legislative process for the development of federal tax legislation.

> When an Internal Revenue Code section and a tax treaty provision appear to conflict, which usually prevails?

> What is a tax treaty? Explain the purpose of a tax treaty. What matters generally are covered in a tax treaty?

> In order for them to have limited practice rights, the IRS requires non-credentialed tax return preparers to participate in the IRS Annual Filing Season Program. What does participation require, and why do you think the IRS has made this change?

> Discuss the powers of taxation that are granted to Congress by the U.S. Constitution. Are any limits placed on the powers of Congress to so tax?

> In what publication(s) would a tax researcher find the official listing of the IRS acquiescences and nonacquiescences to a Tax Court decision?

> In the current year, Dave receives stock worth $125,000 from his employer. The stock is restricted and cannot be sold by Dave for seven years. Dave estimates the stock will be worth $300,000 after the seven years. List as many tax research issues as you

> Many states have an ethics education requirement to become a CPA. Determine each of the following state’s ethics education requirements to become a CPA: a. California b. Texas c. North Carolina d. Your home state

> John and Marsha are married and filed a joint return for the past year. During that year, Marsha was employed as an assistant cashier at a local bank and, as such, was able to embezzle $75,000, none of which was reported on their joint return. Before the

> Joey parked his car on the top of a hill when he went to watch the X Games in San Diego. He did not properly set his brakes or curb the wheels when he parked the car. When he returned from the games, he found his car had rolled down the hill, smashed int

> Answer each of the following questions: a. What is found in Subpart C, § 10.51 of Circular 230? b. In Circular 230, where are the rules on knowledge of client omissions found? c. Describe the requirements of § 1.400.200 of the AICPA Code of Conduct. d. W

> Answer each of the following questions: a. What is found in Subpart A, § 10.7(a) of Circular 230? b. Describe the requirements of § 1.520.001 of the AICPA Code of Conduct. c. Which SSTS discusses whether a member may rely without verification on informat