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(BQ) Part 1 book Federal tax research has contents: Introduction to tax practice and ethics, tax research methodology, constitutional and legislative sources, administrative regulations and rulings, judicial interpretations, tax services and periodicals,...and other contents.
Federal Tax Research EIGHTH EDITION William A Raabe, Ph.D., CPA The Ohio State University Gerald E Whittenburg, Ph.D., CPA San Diego State University Debra L Sanders, Ph.D., CPA Washington State University Australia Canada Mexico Singapore Spain United Kingdom United States Federal Tax Research, 8th edition William A Raabe, Gerald E Whittenburg, Debra L Sanders VP/Editorial Director: Jack W Calhoun Editor-in-Chief: Rob Dewey Acquisitions Editor: Keith Chasse Senior Developmental Editor: Craig Avery © 2009, 2005 South-Western, a part of Cengage Learning ALL RIGHTS RESERVED No part of this work covered by the copyright herein may be reproduced, transmitted, stored or used in any form or by any means graphic, electronic, or mechanical, including but not limited to photocopying, recording, scanning, digitizing, taping, Web distribution, information networks, or information storage and retrieval systems, except as permitted under Section 107 or 108 of the 1976 United States Copyright Act, without the prior written permission of the publisher Marketing Manager: Kristen Hurd Content Project Manager: Jennifer A Ziegler For product information and technology assistance, contact us at Manager of Technology, Editorial: John Rich Cengage Learning Academic Resource Center, 1-800-423-0563 Website Project Manager: Brian Courter Manufacturing Coordinator: Doug Wilke Production Service: Newgen, India For permission to use material from this text or product, submit all requests online at www.cengage.com/permissions Further permissions questions can be emailed to permissionrequest@cengage.com Senior Art Director: Michelle Kunkler Internal Designer: Juli Cook Cover Designer: Rose Alcorn Cover Image: © Isabelle Rozenbaum / PhotoAlto Agency RF Collections Library of Congress Control Number: 2007943841 ISBN-13: 978-0-324-65965-8 ISBN-10: 0-324-65965-2 South-Western Cengage Learning 5191 Natorp Boulevard Mason, OH 45040 USA Cengage Learning products are represented in Canada by Nelson Education, Ltd For your course and learning solutions, visit academic.cengage.com Purchase any of our products at your local college store or at our preferred online store www.ichapters.com Printed in the United States of America 11 10 09 08 07 DEDICATIONS This book is dedicated to our academic mentors William A Raabe Norton Bedford Gerald Brighton Christine Purdie Joseph Schultz Eugene Willis Gerald E Whittenburg William H Hoffman James W Pratt John J Willingham Allan R Bailey Debra L Sanders William Raabe Philip M J Reckers Theodore Saldin Robert Wyndelts This page intentionally left blank ABOUT THE AUTHORS William A Raabe, Ph.D., CPA, teaches graduate tax courses at the Fisher College of Business of The Ohio State University, and at the Capital University (OH) Law School He is a leader among business school tax faculty in incorporating developments in technology into curricula for the educational development of tax professionals Dr Raabe’s teaching and research interests focus on multijurisdictional taxation and financial planning, and he is recognized as the leader among business school academics in the fields of state and local income, sales, and property taxation Dr Raabe is the author or editor of approximately twenty books, including SouthWestern Federal Taxation, Schedule M-3 Compliance, and the Multistate Corporate Tax Guide He has received university-wide recognition as the winner of the AMOCO Foundation Award for Teaching Excellence, and the Wisconsin Institute of CPAs named him the Educator of the Year Gerald E Whittenburg, Ph.D., CPA, EA, is a professor in the School of Accountancy at San Diego State University A graduate of the University of Houston, Dr Whittenburg is interested individual and corporate taxation, pension plans, and tax research methodology Dr Whittenburg is also an author of the textbook Income Tax Fundamentals In addition, he has published articles in journals such as Advances in Taxation, Practical Tax Strategies,Taxes—The Tax Magazine, Journal of Taxation of Investments, Journal of Taxation of Employee Benefits, Journal of Taxation of Financial Institutions, Valuation Strategies, Journal of Small Business Strategy, The Tax Adviser, and Journal of Accounting Education He has received numerous awards for teaching, including the Trustee’s Outstanding Faculty Award for the entire California State University System Recently, Dr Whittenburg was awarded a Fulbright Fellowship to the Ukraine In this picture, he is shown in front of St Michael's Church in Kiev Debra L Sanders, Ph.D., CPA, is a professor in the Washington State Unmiversity School of Accounting, Information Systems and Business Law She has received numerous awards for outstanding teaching, research, and service including the Boeing Distinguished Faculty Research Award, the Shell Corporation Outstanding Teacher Award, and the College of Business and Economics Outstanding Service Award Dr Sanders, a graduate of Arizona State University, publishes in both academic and professional journals Her work has appeared in the academic journals Behavioral Research in Accounting, National Tax Journal, The Journal of the American Taxation Association, Advances in Taxation, and The International Journal of Accounting Professional journals that have published her articles include Taxation for Accountants, Taxation for Lawyers, The Review of Taxation of Individuals, Taxes, The Tax Adviser, and Journal of Financial Planning This page intentionally left blank BRIEF CONTENTS Part I The Tax Research Environment Chapter Chapter Introduction to Tax Practice and Ethics Tax Research Methodology 47 Part II Primary Sources of Federal Tax Law 83 Chapter Chapter Constitutional and Legislative Sources 85 Administrative Regulations and Rulings 119 Chapter Judicial Interpretations 149 Part III Research Tools 189 Chapter Tax Services and Periodicals 191 Chapter Legal Services and Internet Sites 233 Chapter Chapter Citators and Other Finding Devices 273 State Tax Services 307 Chapter 10 International Tax Services 349 Part IV Implementing the Research Tools 379 Chapter 11 Communicating Research Results 381 Chapter 12 Chapter 13 Tax Planning 411 Working with the IRS 437 Chapter 14 Tax Practice and Administration: Sanctions, Agreements, and Disclosures 469 Appendix A Time Value of Money Tables 515 Appendix B Appendix C Standard Tax Citations 518 IRS Circular 230 522 Glossary 551 Index 565 vii This page intentionally left blank CONTENTS Preface xv PART I THE TAX RESEARCH ENVIRONMENT Chapter 1: Introduction to Tax Practice and Ethics Elements of Tax Practice Tax Compliance Tax Planning Tax Litigation Tax Research Rules and Ethics in Tax Practice Circular 230 (Complete Text in Appendix C) AICPA Code of Professional Conduct 14 Statements on Standards for Tax Services 19 Sarbanes-Oxley and Taxation 23 ABA Model Code of Professional Responsibility 24 Nonregulatory Ethical Behavior Models 25 Ethical Dilemmas 25 Ethical Reasoning 25 Ethical Professional Behavior 26 Morality 27 Social Responsibility 28 Business Ethics 28 Tax Planning Ethics 28 Other Ethical Standards 29 Ethics Training and Education 31 Tax Research by Certified Public Accountants 32 Historical Developments 32 CPAs and Other Nonattorneys 33 Summary 34 Tax Tutor 34 Key Words 34 Discussion Questions 35 Exercises 38 Research Cases 43 Chapter 2: Tax Research Methodology 47 Outline of the Tax Research Process 48 Step 1: Establish the Facts 49 Step 2: Identify the Issues 50 Step 3: Locate Authority 53 Step 4: Evaluate Authority 56 Step 5: Develop Conclusions and Recommendations 56 Step 6: Communicate the Recommendation 57 Overview of Computerized Tax Research 58 Benefits of Using a Computerized Tax Service 60 Factors in Choosing a Computerized Tax Service 61 Using a Computer in Tax Research 61 Step 1: State the Issue as a Question 62 Step 2: Identify the Key Words 62 Step 3: Construct a Computer Search Query 63 Step 4: Select a Database and Execute the Search 63 Step 5: Interpret and Refine the Search 64 IRS Web Site Research 65 Tax Research on the CPE Exam 65 Summary 70 Tax Tutor 70 Key Words 70 Discussion Questions 71 Exercises 74 Research Cases 78 PART II PRIMARY SOURCES OF FEDERAL TAX LAW 83 Chapter 3: Constitutional and Legislative Sources 85 Sources of Federal Tax Law 86 History of U.S Taxation 86 U.S Constitution 89 Tax Treaties 91 The Legislative Process 93 ix ... receive more favorable Part >>> The Tax Research Environment Exhibit 1- 2: Elements of Tax Practice Tax Practice Tax Research Tax Compliance Tax Planning Tax Litigation tax treatment In a closed... 18 2 PART III RESEARCH TOOLS 18 9 Chapter 6: Tax Services and Periodicals 19 1 Tax Services 19 2 Illustrative Research Example 19 3... 412 Tax Rate Terminology 414 Tax Base 415 Tax Rates 415 Tax Planning in Perspective 417 Fundamentals of Tax