Steps in Conducting Tax Research

Conduct tax research by the following five steps:

1. Investigate the facts and identify the issues.
2. Collect the appropriate authorities.
3. Analyze the research.
4. Develop the reasoning and conclusion.
5. Communicate the results.

Step 1: Investigate the Facts and Identify the Issues

Document the relevant facts of a case. Ask the taxpayer for additional information, as needed. Sometimes the client may fail to provide all the necessary information. Clarify the factual situation in order to conduct efficient tax research. Exercise due professional care in acquiring the facts and identifying the relevant legal issues, regardless of the amount of money at issue. Understand that most cases with the IRS are settled without the necessity of a trial.

Usually, the facts are stated in chronological order. Provide a date for each event. Where facts are documented, provide references where possible. Use the research on the law to help determine the relevance of the facts. It's best to restate the relevant facts for the client to see, in order to check for their accuracy and completeness.

Use an iterative process for identifying the precise legal issue, refining the issue as one develops more sophisticated knowledge of the relevant law. Incorporate in the issue both the critical facts and the precise location within a Code section for the focus of the research. The location of the issue helps show laser-like precision as to the real legal issue. Write ...

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