Tax Research Process

Research Steps
Very few sections of the Internal Revenue Code (IRC) were written specifically for timber activities. Researching your tax question in a systematic way can help you keep on track and avoid a lot of confusion...| continue |

Administrative Procedures
The U.S. Federal Income tax system is based primarily upon an assumption of self-assessment. The IRS uses the examination of returns as an enforcement device to promote such voluntary compliance with the Internal Revenue laws. There are three major parts to examination process, the preliminary review of returns, the examination process, and the appeal process...| continue |

Legislative Sources:
The legislative primary authorities consist of the U.S. Constitution, new tax laws enacted by Congress and incorporated into the Internal Revenue Code, reports issued by congressional committees as new laws are enacted, and treaties with other countries, which are negotiated by the President with the advice and consent of the Senate. Collectively, these authorities are sometimes referred to as statutory authorities. They are generally accorded a higher level of authority than other administrative or judicial primary authorities...| continue |

Administrative Sources:
The Treasury Department is charged with administering the tax laws of the United States, to accomplish this task it makes various pronouncements to explain the Internal Revenue Code. Administrative pronouncements of this type constitute one of the major categories of primary tax authority. There are four major types of pronouncements that may be issued including "regulations", "revenue rulings", "revenue procedures", and "letter rulings." Each of these categories of rulings is issued for a different purpose and carries a different degree of authority...| continue |

Judicial Sources:
Judicial decisions are the third primary source of tax law. Court decisions are official interpretations and applications of the IRC by the judicial branch of the government. In this process, additional tax law is generated that can carry the full force for the statute itself. From a research standpoint it is important to understand the precedential value of court cases, how they are cited, and the process for review of the court's decision. The federal court system consists of three trial courts and two levels of appellate courts. The three trial courts are the U.S. Tax Court, the U.S. District Courts, and the U.S. Court of Federal Claims. The two appellate courts are the U.S. Court of Appeals and the U.S. Supreme Court. All litigation must start in one of the three types of trial courts...| continue |

Tax Services:
Tax services comprise the majority of the secondary sources that are available to help research tax questions. Secondary authorities are useful when conflicting primary authorities exist, when there appears to be no extant primary authority, or when you need an explanation or clarification of the primary authority. As you are researching your tax question you should take care not to rely too heavily upon the secondary authority, and always read any pertinent primary authority that is referred to in the secondary sources...| continue |