Welcome to Bus 223A

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Welcome to Bus 223A

• Tonight
• Introductions
• Goals of course
• Go over syllabus and assignments
• Introductory quiz (not graded)
• Get RIA and CCH access codes and quick demo
• Basics of tax research 6 key steps

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Six Steps of Tax Research

• As identified by the Authors of Wests Federal
  Tax Research

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1 Fact Gathering

• Completed or proposed transaction?
• Dates
• Any related parties?
• Where?
• Any non-tax considerations?

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2 Identify Issues

• Issue of
• Fact
• Law

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3 Find Authority

• First may need to start with secondary
  authority as lead into primary authority
• Always IRC and regs
• If IRC and regs dont answer your question ask
  yourself why and then to a focused search for
  rulings or if no rulings, ck legislative
  histories

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4 Evaluate Authority

• Highest?
• Newest?
• Still good law?
• Truly on point?
• Could it be distinguished from your situation

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5 Conclusions Recommendations

• Exercise knowledge of tax law and client
• Professional judgment

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6 Communication Results

• Memo to file
• Facts, issue, law, analysis, conclusion, next
  steps
• Letter to client
• PLR request
• Article or speech

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Research Memo Format

• Date, To, From, Subject
• Facts
• Issue(s)
• Law
• Analysis (apply law to our facts and issue)
• Conclusion (the short answer details to
  explain that answer are in the Analysis)
• Next steps (complete a form, talk to client,
  etc.)
• Use this format rather than one on page 57. Also
  see sample memo in online materials (Section F).

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Skills Needed

• Research skills
• Knowledge of the tax law
• Reasoning
• Creativity
• Experience
• Keeping up to date
• Efficiency your time and tools are expensive