Primary Authority
This is the highest primary authority.
What is the IRC?
This IRC Section defines gross income.
What is Section 61?
This Checkpoint feature provides a case's history and other citing cases.
What is the citator?
If a position reaches this confidence level, the taxpayer and the adviser will avoid penalties when the IRS disagrees and imposes a tax deficiency.
What is substantial authority?
This doctrine is exemplified in court cases as "the fruit and tree doctrine."
What is the assignment of income doctrine?
This is the highest authority issued by the IRS.
What are Treasury Regulations?
This IRC Section describes ordinary and necessary business expenses.
What is Section 162?
This secondary source in Checkpoint is written by RIA editors.
What is FTC or the Federal Tax Coordinator?
Treasury wrote these best practice standards for tax practitioners.
What is Circular 230?
This Checkpoint Edge symbol on the left side of an IRC or Regulation section is helpful by giving the exact citation when reading a long document.
What is the compass?
This authority is only binding on the requesting/paying taxpayer.
What is a Private Letter Ruling?
This IRC Section describes the accuracy related penalty.
What is Section 6662?
This secondary source in Checkpoint provides short summaries of court cases and rulings.
What are annotations?
This confidence level has some merit but requires disclosure of the issue in the tax return.
What is reasonable basis?
This Checkpoint Edge feature tells the researcher where he/she is in the book of reference material.
What is Contents?
The IRS may issue this authority in response to a tax court decision to inform taxpayers whether they agree with the court.
What is an AOD or Action on Decision?
This designation is given to an IRC section when first enacted in law.
What is PL or Public Law?
This type of search finds authority using keywords and proximity connectors?
What is a Terms & Connectors search?
The AICPA wrote these best practice standards for tax practitioners.
What are the SSTS or the Statements on Standards for Tax Practitioners?
The IRS tried to argue this taxpayer had constructive receipt of a car after winning the national football championship. He also beat Johnny Majors in the Heisman trophy race.
Who is Paul Hornung?