Test Bank for South-Western Federal
Taxation Comprehensive, Chapter 2
(47th Edition Young)
Acquiescence - ANSAgreement by the IRS on the results reached in certain judicial decisions;
sometimes abbreviated Acq. or A.
Circuit Court of Appeals - ANSAny of 13 Federal courts that consider tax matters appealed from
the U.S. Tax Court, a U.S. District Court, or the U.S. Court of Federal Claims. Appeal from a
U.S. Court of Appeals is to the U.S. Supreme Court by Certiorari.
Citator - ANSA tax research resource that presents the judicial history of a court case and traces
the subsequent references to the case. When these references include the citating cases'
evaluations of the cited case's precedents, the research can obtain some measure of the
efficacy and reliability of the original holding.
Court of original jurisdiction - ANSThe Federal courts are divided into courts of original
jurisdiction and appellate courts. A dispute between a taxpayer and the IRS is first considered
by a court of original jurisdiction (i.e., a trial court). The four Federal courts of original jurisdiction
are the U.S. Tax Court, the U.S. District Court, the Court of Federal Claims, and the Small
Cases Division of the U.S. Tax Court.
Determination letter - ANSUpon the request of a taxpayer, the IRS will comment on the tax
status of a completed transaction. Determination letters frequently are used to determine
whether a retirement or profit sharing plan qualifies under the Code, and to determine the
tax-exempt status of certain nonprofit organizations.
Federal District Court - ANSA trial court for purposes of litigating Federal tax matters. It is the
only trial court in which a jury trial can be obtained.
Finalized Regulation - ANSThe U.S. Treasury Department Regulations (abbreviated Reg.)
represent the position of the IRS as to how the Internal Revenue Code is to be interpreted. Their
purpose is to provide taxpayers and IRS personnel with rules of general and specific application
to the various provisions of the tax law. Regulations are published in the Federal Register and in
all tax services.
Interpretive Regulation - ANSA Regulation issued by the Treasury Department that purports to
explain the meaning of a particular Code Section. An interpretive Regulation is given less
deference than a legislative Regulation.
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