Tax Research Methodology
Tax research methodology is the systematic process of identifying tax issues, locating relevant authorities, analyzing their applicability, and communicating conclusions.
Explanation
The research process follows six steps: identify the issue, gather facts, locate applicable authorities, analyze authorities, develop conclusions, and communicate results. Primary authorities include the Internal Revenue Code, Treasury regulations, revenue rulings, revenue procedures, and court decisions. Secondary authorities (textbooks, tax services, articles) are not binding but aid interpretation. The hierarchy of authority matters — the IRC is the highest statutory authority, followed by Treasury regulations, then administrative and judicial guidance.
Key Points
- •Six-step process: identify, gather facts, locate authority, analyze, conclude, communicate
- •Primary authorities: IRC, regulations, rulings, court decisions
- •IRC > Treasury regulations > revenue rulings > court decisions (hierarchy)
Exam Tip
The Internal Revenue Code is always the starting point for tax research — Treasury regulations interpret the Code but cannot override it.
Frequently Asked Questions
Related Topics
Individual Tax Planning
Individual tax planning involves strategies to minimize a taxpayer's current and future tax liability through timing of income and deductions, use of tax-advantaged accounts, and entity structure decisions.
Corporate Tax Planning
Corporate tax planning involves structuring business transactions and operations to minimize the overall tax burden while complying with tax laws and regulations.
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