Fundamentals of Tax research

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NYT 11.4

Citing Revenue Rulings

Provide the citation to the following Revenue Rulings:

1. The 23rd Revenue Ruling issued during 2017 and that can be found beginning on page 546

of the Internal Revenue Bulletin issued during the 49th week of 2017:

2. The 60th Revenue Ruling issued during 1998 and that can be found beginning on page 751

of the second volume of that year's Cumulative Bulletin:

NYT 11.5

PLRs and TAMs

Answer the following questions based on the information just provided.

1. List two ways in which PLRs and TAMs differ.

2. What does the citation "PLR 201815005" tell you about this ruling?

EXERCISE

6. Using a Citation Search or a Keyword Search in the IRS Rulings & Releases database, find Revenue Ruling

2011-29.

a. Provide the citation to this ruling.

b. What Code sections are discussed in the ruling?

c. What are the facts of the ruling?

d. What issue is decided in the ruling?

e. What did the IRS conclude with respect to this issue?

f When viewing the ruling, click on the "FTC" button at the top. What are the paragraph numbers and headings

or titles under which this ruling is cited in the Federal Tax Coordinator 2d?

g. When viewing the ruling check the citator to see in what cases and rulings Revenue Ruling 2011-29 was cited.

What did you find? Did Revenue Ruling 2011-29 affect any prior ruling(s)? If so, which one(s) and how?

7. Using a Citation Search or a Keyword Search in the IRS Rulings & Releases database, find Revenue Procedure

2013-30.

a. Provide the citation to this procedure.

b. Which Code section is discussed in this procedure?

c. What type of relief can taxpayers request of the IRS pursuant to this procedure?

d. When viewing the procedure, click on the "Annas" button at the top. What are the paragraph numbers and

headings or titles under which this procedure is annotated in the USTR Annotations (RIA)?

e. When viewing the procedure, check the citator to see its "judicial history" and in what other sources of tax

law Revenue Procedure was cited. What did you find?