1. Tax Research (Day 1) Dr. Richard Ott ACCTG 833, Fall 2007
Chapter
Tax Research (Day 1) Dr. Richard Ott ACCTG 833, Fall 2007

2. Tax Research Process Contexts:
Closed-fact or tax compliance situations
Open-fact or tax planning situations

3. Tax Research Process Goal of tax planning: Must consider:
Maximize NPV of after-tax cash flows
Must consider:
Tax consequences to all parties
Nontax costs
Financial reporting consequences (publicly traded corporations)

4. Tax Research Process Determine the Facts
Identify issues and research questions
Locate applicable authorities
Evaluate authorities (conflicts)
Analyze facts in terms of the authorities
Communicate conclusions and recommendations (usually written)

5. Sources of Tax Law Statutory authorities Administrative authorities
Judicial authorities

6. Statutory Authorities

7. Statutory Authorities
U.S. Constitution, 16th Amendment (1913)
Tax Treaties
The Internal Revenue Code

8. Internal Revenue Code
The Internal Revenue Code is the law as enacted by Congress, signed by President
Highest weight of authority in conflicts

9. Internal Revenue Code
The Internal Revenue Code is Title 26 of the U.S. Code and is organized as follows: A. Subtitles Chapters C. Subchapters III. Parts A. Subparts Sections

10. The Internal Revenue Code
Sections are numbered sequentially from the beginning to the end of Title 26 and are divided as follows: Section (g) Subsections (1) Paragraphs (A) Subparagraphs (i) Clauses

11. The Internal Revenue Code
Examples of acceptable citations:
Internal Revenue Code §351(g)(1)(A)(i)
IRC §351(g)(1)(A)(i)
IRC Section 351(g)(1)(A)(i)
Code §351(g)(1)(A)(i)
Code Section 351(g)(1)(A)(i)
Section 351(g)(1)(A)(i) of the IRC
Section 351(g)(1)(A)(i) of the Code
26 USC §351(g)(1)(A)(i)

12. For Next Class:
Read Chapter 1 through page 1-13 in the Prentice Hall textbook
Note to self: There was ½ hour of extra class time available on each of Days 1 and 2 and 20 minutes extra time on Day 3. Next time combine Chapter 1 into just 2 days.