In short
Tax research generally follows these steps: establish the facts, identify the issues, find the relevant authority, evaluate it, reach a conclusion and communicate it, usually in a memo to the file and a letter to the client.
Key takeaways
- Primary authority includes the Code, regulations, court decisions and administrative rulings; secondary sources include treatises and articles.
- A citator shows whether a case or ruling is still good law.
- Changes in the facts can change the answer, so assumptions should be documented.
Where it's tested
TCP: Tax Research & Documentation — study notes, a five-minute revision sheet and practice questions.
Practise: 3 questions
Question 1 of 3 · 0 answered
A tax practitioner finds a Private Letter Ruling issued to another taxpayer that directly supports the client's intended position. How should the practitioner treat it?