Advanced Taxation, Chapter 4: "Administrative Regulations and Rulings" definitions

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16 Terms

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Internal Revenue Service

(4.1) A division of the U.S. Treasury Department that administers tax laws.

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IRC Sec. 7805

(4.1) A section of the Internal Revenue Code that allows the Secretary of the U.S. Treasury Department to prescribe rules and regulations necessary to administer the IRC.

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Regulation

(4.1) A pronouncement of the tax law that is issued by the IRS and Treasury Department. It is considered to be the official interpretation of the IRC.

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Proposed Regulation

(4.1) A form of regulation that is useful for understanding the IRS’ current position, but does not have an effect on the law.

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Final Regulation

(4.1) A form of regulation that is finalized and published as a Treasury Decision (TD).

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Temporary Regulation

(4.1) A form of regulation that holds the same weight as final regulations, but expire after three years of issuance.

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Effective Date of Regulation

(4.1) The date a regulation becomes effective.

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Revenue Ruling

(4.1) A pronouncement of the tax law that indicates how the IRS will treat a given taxpayer transaction.

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Revenue Procedure

(4.1) A pronouncement of the tax law that instructs taxpayers on how to comply with IRS internal practices and procedures.

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Private Letter Ruling

(4.1) A kind of letter ruling that is issued by the National Office of the IRS in response to a taxpayer’s request on a specific tax issue in a proposed transaction.

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Technical Advice Memoranda

(4.1) A kind of letter ruling that is requested by an IRS agent during an audit regarding a completed transaction.

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Determination Letter

(4.1) A kind of letter ruling that is issued on a taxpayer’s request on a specific tax issue (usually not controversial) related to a completed transaction.

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Internal Revenue Bulletin

(4.5) A bulletin created by the IRS, that is used to publish rulings, procedures, regulations, court decisions, and other information valuable to tax professionals. 

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Acquiescence

(4.5) An instance when the IRS issues a statement indicating that while it may or may not agree with a decision, they will follow it in similar situations.

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Nonacquiescence

(4.5) An instance when the IRS issues a statement indicating they disagree with a decision and will only follow it in specific cases.

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Chief Counsel Memoranda

(4.5) A memoranda issued by the IRS’ Office of Chief Counsel that is disseminated as a guide to politics, procedures, instructions, and other information.