Tax Research

ACCT 6356.501 Tax Research – Fall 2022

Name __________________

RESEARCH ASSIGNMENT 4

Internal Revenue Bulletin

( Please submit as a Word document by email by 4:00 p.m. next Thursday, 9/22. )

This assignment is worth up to a maximum of five (5) points (see Note below). Your answer should be written in your own words without any “cutting & pasting” from the source document(s) you cite except that very brief quotations are acceptable with proper attribution.

Points will be deducted for, among other things, (i) spelling and grammatical er-rors that Word highlighted but you failed to correct and (ii) other egregious errors, including substantive misstatements.

Any submissions received after 4:00 p.m. are worth a maximum of three (3) points. Submissions not received by 7:00 p.m. will not be scored (zero points).

Consult the Citation Style guide in the Syllabus. Be sure to include your name on your work.

Note: This is a two-part assignment. Part 1 is worth up to three points. Part 2 is worth up to two points.

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Part 1. The accomplished tax professional pictured above is Sharyn Fisk. She leads the IRS Office of Professional Responsibility (OPR) which, among other things, has jurisdiction over Circular 230 (31 C.F.R. § 10), the rules of ethics for those who “practice before the IRS.”

From time to time OPR issues an “Announcement” reporting disciplinary sanc-tions against attorneys, CPAs, and other practitioners, typically for a serious vio-lation of Circular 230. Locate and properly cite the most recent OPR announce-ment of such sanctions against any Texas CPA(s). Also (i) name the CPA(s), (ii) identify her or his Texas city, (iii) name the specific disciplinary sanction imposed and (iv) the “as of” date of that sanction.

Part 2. Staying with § 911 from RA 3, you recall that a U.S. taxpayer qualifies for the foreign earned income exclusion by having her or his “tax home” in a foreign country and either (i) being a “bona fide resident” of that foreign country in which s/he earns income or (ii) being present there for a certain duration. But Congress has granted the IRS discretion (§ 911(d)(4)) to declare that war, civil unrest, or similar “adverse conditions” have made a particular location so dangerous that the time requirement of the physical presence test is either waived or relaxed.

The IRS in fact does exercise its § 911(d)(4) discretion periodically and usually announces it by way of issuing a revenue procedure (Rev. Proc.). Find and properly cite the most recent such item and state for exactly what part(s) of the world the IRS waived or relaxed the usual § 911 requirements, as well as the accompanying effective date(s).

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