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Related Flashcards
Cards In This Set
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DIF
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Discriminate Function System
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Business Purpose Doctrin
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IRS can disallow transactions with no business purpose
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Step-Transaction Doctrine
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IRS can collapse a series of transactions into on eto determine tax liability
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Substance-over-form doctrine
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IRS can reclassify transactions according to substance
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Economic Substance Doctrine
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1. Must meaningfully change taxpayer's economic position2. Must be a substantial purpose for transaction
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Document perfection
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Checks for math errors, etc
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Information Matching Programs
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Compares tax return information with other IRS data
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Tax Court
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National court; Tax Experts, do not pay tax 1st, appeals to US CIrcuit Courts of Appeal 1-11 and DC
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US District Court
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Local court; Possible jury trial; generalists; pay tax 1st, appeals to US Circuit Courts of Appeal 1-11 and DC
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US Court of Federal Claims
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National court; Generalists; Pay tax 1st; appeals to US Circuit Court of Appeals for the Federal Circuit
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Primary Sources
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Statutory (Internal Revenue Code, Committee reports: Senate, House, Tax Treaties), Judicial (Supreme Court Opinion), Administrative (IRS pronouncements,Treasury Regulations, Revenue Rulings)
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Secondary Sources
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Articles, RIA Federal Tax Coordinator, Tax research services, quick reference sources (even if published by IRS)
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Revenue Rulings
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Administrative Primary Less authoritative weight, but they provide a much more detailed interpretation of the Code
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Treasury Regulations
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Administrative Primary Treasury departments official interpretaion of the IRC. Forms: Final, Temporary, ProposedPurposes: INterpretative, Procedural, Legislative
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Revenue procedures
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Administrative primary Explain in great detail IRS practice and procedures in administering tax law
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