Question 1

Final regulations can take effect on any of the following dates except

Accepted Answer

A) the effective date of the statutory language they interpret, provided they are issued within 18 months of the date of the change to the statute. 
B) the date on which final regulations were proposed. 
C) the date on which related temporary regulations were first published in the Federal Register. 
D) the date on which they were issued in final form. 
A) the effective date of the statutory language they interpret, provided they are issued within 18 months of the date of the change to the statute. 
B) the date on which final regulations were proposed. 
C) the date on which related temporary regulations were first published in the Federal Register. 
D) the date on which they were issued in final form. A

Question 2

Are letter rulings of precedential value to third parties?

Accepted Answer

Not really. A letter ruling is binding only on the taxpayer to whom the ruling was issued. However, the rulings can be useful in proving insights as to the IRS opinion about the tax consequences of various transactions.

Question 3

The facts must be determined. However, some facts may not have occurred in an open-fact situation. Where facts have not yet occurred, it is useful to review tax research material to determine which facts would produce the most favorable outcome.

Accepted Answer

In situations where the facts must be determined, it is important to carefully review all available information and evidence to establish the most accurate and reliable understanding of the situation. However, it is also important to acknowledge that in some cases, certain facts may not be readily available or may not have occurred in an open-fact situation.

In instances where certain facts have not yet occurred, it can be beneficial to conduct thorough tax research to identify and analyze potential scenarios and outcomes. By reviewing tax research material, it is possible to determine which set of facts would result in the most favorable outcome from a tax perspective.

Ultimately, the goal is to ensure that all relevant facts are considered and that the most advantageous approach is taken in accordance with tax laws and regulations. This may involve careful analysis, consultation with experts, and a comprehensive review of available resources to make informed decisions and achieve the best possible outcome.

Question 4

Under what circumstances might a tax advisor find the provisions of a tax treaty useful?

Accepted Answer

A tax advisor might consult th

Question 5

The primary citation for a federal circuit court of appeals case would be

Accepted Answer

A) 40 AFTR 2d 78-1234. 
B) 44 F.Supp. 403. 
C) 3 F.3d 134. 
D) 79-2 USTC & 9693. 
A) 40 AFTR 2d 78-1234. 
B) 44 F.Supp. 403. 
C) 3 F.3d 134. 
D) 79-2 USTC & 9693.

Question 6

Which of the following is a true statement regarding primary authority of tax law?

Accepted Answer

A) Articles in The Journal of Taxation are viewed as primary authority. 
B) Primary authority includes the Code, as well as administrative and judicial interpretations. 
C) The Bloomberg BNA Daily Tax Reporter is a source of primary tax authority. 
D) Tax services are sources of primary tax authority. 
A) Articles in The Journal of Taxation are viewed as primary authority. 
B) Primary authority includes the Code, as well as administrative and judicial interpretations. 
C) The Bloomberg BNA Daily Tax Reporter is a source of primary tax authority. 
D) Tax services are sources of primary tax authority.

Question 7

If the U. S. District Court for Rhode Island, the Tax Court, and the Eleventh Circuit have all ruled on a particular issue, then what precedents have been set for which courts in the future?

Accepted Answer

Any U. S. District court within the Elev

Question 8

Which of the following citations denotes a regular decision of the Tax Court?

Accepted Answer

A) 41 TCM 1272 
B) 35 T.C. 1083 (2003) 
C) 39 AFTR 2d 77-640 
D) all of the above 
A) 41 TCM 1272 
B) 35 T.C. 1083 (2003) 
C) 39 AFTR 2d 77-640 
D) all of the above

Question 9

What is the purpose of a citator?

Accepted Answer

Citators give a history of the

Question 10

The Tax Court decides an expenditure is deductible in the year the issue was first litigated. The government appealed and won a reversal in the Ninth Circuit Court of Appeals. It is the only appellate decision regarding the issue. If and when the Tax Court encounters this issue again, how will it hold?

Accepted Answer

The Tax Court will hold that t

Question 11

When the Tax Court follows the opinion of the circuit court of appeals to which the case is appealable, the court is following the

Accepted Answer

A) Golsen rule. 
B) Acquiescence rule. 
C) Forum shopping rule. 
D) Conformity rule. 
A) Golsen rule. 
B) Acquiescence rule. 
C) Forum shopping rule. 
D) Conformity rule.

Question 12

Why does a researcher use a citator?

Accepted Answer

A) to check on authorities issued subsequent to a court decision 
B) to determine whether a private letter ruling exists on the subject 
C) for examples of the application of a tax provision 
D) none of the above 
A) to check on authorities issued subsequent to a court decision 
B) to determine whether a private letter ruling exists on the subject 
C) for examples of the application of a tax provision 
D) none of the above

Question 13

When a court discusses issues not raised by the facts, the comments

Accepted Answer

A) are excluded from the formal court opinion. 
B) may be referenced by the parties in other cases having the same facts. 
C) are not dicta. 
D) will cause the court's decision to be declared invalid. 
A) are excluded from the formal court opinion. 
B) may be referenced by the parties in other cases having the same facts. 
C) are not dicta. 
D) will cause the court's decision to be declared invalid.

Question 14

Identify which of the following statements is false.

Accepted Answer

A) When a court opinion discusses facts and issues on which the court does not rule, the comments are called dicta. 
B) Dicta in a court opinion has no influence on other tax proceedings. 
C) Published articles and tax services are examples of secondary sources of authority. 
D) Dicta are not authoritative. 
A) When a court opinion discusses facts and issues on which the court does not rule, the comments are called dicta. 
B) Dicta in a court opinion has no influence on other tax proceedings. 
C) Published articles and tax services are examples of secondary sources of authority. 
D) Dicta are not authoritative.

Question 15

What is the purpose of Treasury Regulations?

Accepted Answer

The Treasury Department issues regulatio

Question 16

What is an information release?

Accepted Answer

The IRS issues information rel

Question 17

Regulations issued prior to the latest tax legislation dealing with a specific Code section are still effective to the extent they do not conflict with the provisions in the new legislation.

Accepted Answer

A) True 
 B)False

Question 18

Discuss the differences and similarities between regular and memorandum decisions issued by the U.S. Tax Court.

Accepted Answer

Differences:
1. Regular decisions involv

Question 19

Describe the format of a client memo.

Accepted Answer

A client memo should include a statement

Question 20

Identify which of the following statements is false.

Accepted Answer

A) The number "5" in the citation Reg. Sec. 1.166-5 refers to the paragraph number. 
B) The Cumulative Bulletin is issued semiannually while the Internal Revenue Bulletin is issued weekly. 
C) The citation Rev. Rul. 2006-5, I.R.B. 2006-1, 33, indicates that the revenue ruling can be found on page 33 of the 1st I.R.B. for 2006. 
D) All of the above are false. 
A) The number "5" in the citation Reg. Sec. 1.166-5 refers to the paragraph number. 
B) The Cumulative Bulletin is issued semiannually while the Internal Revenue Bulletin is issued weekly. 
C) The citation Rev. Rul. 2006-5, I.R.B. 2006-1, 33, indicates that the revenue ruling can be found on page 33 of the 1st I.R.B. for 2006. 
D) All of the above are false.

Final regulations can take effect on any of the following dates except

Are letter rulings of precedential value to third parties?

The facts must be determined. However, some facts may not have occurred in an open-fact situation. Where facts have not yet occurred, it is useful to review tax research material to determine which facts would produce the most favorable outcome.

Under what circumstances might a tax advisor find the provisions of a tax treaty useful?

The primary citation for a federal circuit court of appeals case would be

Which of the following is a true statement regarding primary authority of tax law?

If the U. S. District Court for Rhode Island, the Tax Court, and the Eleventh Circuit have all ruled on a particular issue, then what precedents have been set for which courts in the future?

Which of the following citations denotes a regular decision of the Tax Court?

What is the purpose of a citator?

When the Tax Court follows the opinion of the circuit court of appeals to which the case is appealable, the court is following the

Why does a researcher use a citator?

When a court discusses issues not raised by the facts, the comments

Identify which of the following statements is false.

What is the purpose of Treasury Regulations?

What is an information release?

Regulations issued prior to the latest tax legislation dealing with a specific Code section are still effective to the extent they do not conflict with the provisions in the new legislation.

Discuss the differences and similarities between regular and memorandum decisions issued by the U.S. Tax Court.

Describe the format of a client memo.

Identify which of the following statements is false.

An Introduction to Taxation

Determination of Tax

Gross Income: Inclusions

Gross Income: Exclusions

Property Transactions: Capital Gains and Losses

Deductions and Losses

Itemized Deductions

Losses and Bad Debts

Employee Expenses and Deferred Compensation

Depreciation, Cost Recovery, Amortization, and Depletion

Accounting Periods and Methods

Property Transactions: Nontaxable Exchanges

Property Transactions: Section 1231 and Recapture

Special Tax Computation Methods, Tax Credits, and Payment of Tax

Corporations

Partnerships and S Corporations

Taxes and Investment Planning

Filters

Exam 15: Tax Research

Final regulations can take effect on any of the following dates except

Are letter rulings of precedential value to third parties?

The facts must be determined. However, some facts may not have occurred in an open-fact situation. Where facts have not yet occurred, it is useful to review tax research material to determine which facts would produce the most favorable outcome.

Under what circumstances might a tax advisor find the provisions of a tax treaty useful?

The primary citation for a federal circuit court of appeals case would be

Which of the following is a true statement regarding primary authority of tax law?

If the U. S. District Court for Rhode Island, the Tax Court, and the Eleventh Circuit have all ruled on a particular issue, then what precedents have been set for which courts in the future?

Which of the following citations denotes a regular decision of the Tax Court?

What is the purpose of a citator?

When the Tax Court follows the opinion of the circuit court of appeals to which the case is appealable, the court is following the

Why does a researcher use a citator?

When a court discusses issues not raised by the facts, the comments

Identify which of the following statements is false.

What is the purpose of Treasury Regulations?

What is an information release?

Regulations issued prior to the latest tax legislation dealing with a specific Code section are still effective to the extent they do not conflict with the provisions in the new legislation.

Discuss the differences and similarities between regular and memorandum decisions issued by the U.S. Tax Court.

Describe the format of a client memo.

Identify which of the following statements is false.

An Introduction to Taxation

Determination of Tax

Gross Income: Inclusions

Gross Income: Exclusions

Property Transactions: Capital Gains and Losses

Deductions and Losses

Itemized Deductions

Losses and Bad Debts

Employee Expenses and Deferred Compensation

Depreciation, Cost Recovery, Amortization, and Depletion

Accounting Periods and Methods

Property Transactions: Nontaxable Exchanges

Property Transactions: Section 1231 and Recapture

Special Tax Computation Methods, Tax Credits, and Payment of Tax

Corporations

Partnerships and S Corporations

Taxes and Investment Planning

Filters