Course ID: TRSM

Tax Research: Sources, Methods, And Documentation

Exactly how do you decide that a tax return position is “more likely than not” to be sustained when examined? If “substantial authority” is what you need to support a return position, how do you determine that? What is the value of proposed regulations? What authority are IRS return instructions? Which Court decision is the strongest authority? Will a 2004 private ruling be “substantial authority” for a 2008 return position? OK, so you found the answer, what information do you need to cite it correctly? Will your opinion, when issued, meet the requirements of Circular 230, Section 10.37? When should return positions be disclosed on Form 8275, or Form 8886? Answers to these and 100 more questions about tax research procedures and authority are part of this program.

  • Understand common tax terminology
  • Locate and evaluate authority on federal tax matters for application of reliance standards in Sec. 6694, FIN 48, and section 10.34 of circular 230
  • Comply with professional standards relating to documenting information on which your tax research and resulting opinions are based
  • Confirm conclusions by cross referencing code and regs to commentaries and vice-versa
  • Clearly communicate results of your research in good form
  • Recognize abusive tax transactions and avoid penalties

  1. Relative weight of authorities
  2. Use of commonly available reference materials
  3. Relationship of various types of authority
  4. Frequently overlooked authority
  5. Evaluation of”more likely than not” tax return positions vs. “substantial authority” and/or “reasonable basis”
  6. IRC Sec. 6662 reliance standards and penalties
  7. Convenient format for summary of research results
  8. Treasury Circular 230, paragraphs 33, 34, 35 and 37
  9. Electronic research options and tools

CPAs who want to improve their tax research and documentation skills


Nichols Patrick CPE, Inc



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