Discussion #6
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Feb 20, 2024
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Chapter 4 Discussion #14:
Identify three types of letter rulings that are of interest to the tax researcher. Indicate whether each of these rulings is published by the IRS.
Private Letter Ruling
– issued by the National Office of the IRS in response to a taxpayers request for the IRS’s position on a specified tax issue. Letter rulings are of interest to tax researchers because they can help taxpayers avoid certain statutory penalties and they may indicate how the IRS would treat certain situations. The IRS does publish these rulings if they come across an unusual transaction that could be of
general interest or see multiple ruling requests for similar situations. Before the IRS publishes these rulings, they are purged of any reference to the taxpayer’s name or identifying information. Technical Advice Memorandum (TAM)
– issued by the IRS’s office of the Chief Counsel, typically responding to a request from the IRS official that stems from an audit or a taxpayer request for refund. These can not be relied upon by other taxpayers because they apply strictly to the taxpayer’s situation that requested it. They are of interest to a tax researcher because it can give insight into the IRS’s thinking relative to a problem area in taxation. These are not included in any publications, but they are open to public inspection via commercial tax research services. Determination Letter
– issued by the local office of the IRS rather than the national office and similar in purpose to a PLR. They typically deal with issues and transactions that are not overtly controversial. They
are not published by the IRS, but they are open to public inspection via commercial tax research services.
https://ebooks.cenreader.com/#!/reader/74e4278a-8396-4f9e-a896-5c66c2f6372f/page/
b85ade7f33772698eb1d73902fe3b92c
Chapter 3 Exercise #31:
Locate the most recent committee reports associated with each of the following code sections (if any) using a tax service such as Checkpoint. Give the citation to the committee report, the public law number, and a brief explanation of how the public law is amending the code.
§ 6103
– Committee Reports for HR 114-542, P.L.114-184. The public law is amending the code by permitting specified Federal law enforcement officials to seek an ex parte court order for the disclosure of return and return information in cases of missing or exploited children.
https://checkpoint.riag.com/app/main/doc?
usid=51cae7u27627e&DocID=i31ebdfb78b01eae984acf3586990e9dc&collId=T0tocleg114b&docTid=T0P
LCOMREP%3A8221.1-
1&feature=tcheckpoint&lastCpReqId=24b491&searchHandle=i0ad82d080000018d584fd19e9b61ef6d
§ 7345
– Committee Reports for CONF 114-357, P.L. 114-194. The public law is amending the code by giving authority to deny or revoke passports for individuals who have seriously delinquent tax debt (>$50,000).
https://checkpoint.riag.com/app/main/doc?
usid=51cae7u27627e&DocID=i509e7fcfbe57cf0d974fbceffaa6af61&collId=T0tocleg114b&docTid=T0PLC
OMREP%3A7946.1-
1&feature=tcheckpoint&lastCpReqId=24bc76&searchHandle=i0ad832f10000018d5868b182ad558db1
§ 4980H
– Committee Reports for S114-3, P.L. 114-94. The public law is amending the code by allowing companies to exclude employees from their large employer count who have medical coverage through (1)
a program for members of the armed forces, including coverage under the TRICARE program, or (2) under a VHA health care program, as determined by the Secretary of Veterans Affairs, in coordination with the Secretary of Health and Human Services and the Secretary
https://checkpoint.riag.com/app/main/doc?
usid=51cae7u27627e&DocID=ic54c7b93d1e7eec3fa1af377e86c0713&collId=T0tocleg114b&docTid=T0P
LCOMREP%3A7690.1-
1&feature=tcheckpoint&lastCpReqId=24bfd1&searchHandle=i0ad832f10000018d5873b202deba9c9c
Chapter 4 Practice Research #79:
Can proceeds from a life insurance policy be included in a decedent’s gross estate if the policy was purchased by an S corporation for an employee-shareholder?
Yes, proceeds from a life insurance policy would be included in the decedent’s gross estate if the policy was purchased by an S corp. Because the decedent is a shareholder, which means they could have had incidents of ownership in the policy at the time of death. The only way to get around this is if the shareholder transferred its ownership to another person or entity more than three years before their death. https://checkpoint.riag.com/app/view/previewDocNew?
feature=tcheckpoint&lastCpReqId=24d096&preview=y&tabPg=40&DocID=i0f0978c219d811dcb1a9c7f8e
e2eaa77&SrcDocId=T0PLR2010%3A12393.1-1
https://checkpoint.riag.com/app/main/doc?
usid=51cae7u27627e&DocID=i490e81c2ee4a499dceb8db0a7a6eccb9&collId=T0toc096&docTid=T0PLR
2010%3A12393.1-
1&feature=tcheckpoint&lastCpReqId=24d06a&searchHandle=i0ad82d080000018d58991dd996f64716
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