ACC 455 Week 1

Individual Tax Return Position Paper

Suppose you have a concern about taking a particular position on a tax return.

Write a 700- to 1,050-word paper that discusses the following:

What are the primary sources of tax law?

What are the secondary sources of tax law?

What is substantial authority?

What is the role of the courts and the Internal Revenue Service in interpreting and applying the sources of tax law?

Format your paper consistent with APA guidelines.

Discussion Questions

What business entities are available for a new business? What are the tax and nontax advantages of each form? Select two business types and provide an example of when that selection is most appropriate from a tax perspective and from a nontax perspective.

Once a business has elected its tax status using check-the-box regulations, what options are available if it needs to change its tax status? What should a business consider before electing to change its tax status?

Do the following decisions have the same precedential value: (1) Tax Court regular decisions, (2) Tax Court memo decisions (3) decisions under the small cases procedure of the Tax Court? Why? Which of the following sources do you think would be most beneficial for your client: (1) Tax Court regular decisions, (2) Tax Court memo decisions, (3) decisions under the small cases procedure of the Tax Court, or (4) Fifth Circuit Court of Appeals?