Tax Research

ACCT 6356.501 Tax Research – Fall 2022

Name __________________

RESEARCH ASSIGNMENT 8

Tax Practice & Procedure

( Please submit as a Word document by email by 4:00 p.m. on Thursday, 10/27. )

This assignment is worth up to a maximum of six (6) points – two items worth up to three (3) points each. Your work 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 if properly attributed. Points will be deducted for (i) spelling and grammatical errors that Word highlighted but you failed to correct and (ii) other egregious errors, including substantive misstatements.

Any submissions received after 4:00 p.m. will be worth up to four points only. Submissions not received by 7:00 p.m. will not be scored (zero points).

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Item 1: One of the delightful events of any tax year is the early January release of the National Taxpayer Advocate’s Annual Report to Congress. In turn, one of the most anticipated parts of that Report is the annual “top 10 list” – that is, the Most Litigated Issues list.

The 2021 Annual Report contained a surprise – namely, the Most Litigated Issues list became two lists: (1) the “historical approach” list, naming the “top 10” by actual Tax Court opinions issued (as has always been done), and (2) the “revised methodology” list based on petitions filed (rather than decisions issued).

Curiously (or not), the top two of the top 10 on both lists were exactly the same. Your task is to locate the 2021 Annual Report, then located the Most Litigated Issues discussion, then identify the top two read the accompanying commentary. Finally, in around 500 words, explain your view (opinion) as to why these two issues are such “popular” tax controversy topics.

Item 2: Locate the most recent annual summary report of the IRS Art Advisory Panel and study it. Explain in around 250 words what the purpose and function of the Panel is, and how it operates. Also find, properly cite, and summarize any Tax Court case (T.C. or Memo opinion) in which the Art Advisory Panel’s work was relevant and relied on (or not). Be sure to explain exactly how and/or why the Tax Court did or did not rely on the Panel’s work in the circumstances.

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