The memo summarizes the tax issues related to Alvarez Tech Corporation's planned purchase and use of a new corporate jet. It outlines that the president, Juan Alvarez, wants to ensure the jet expenses are fully deductible and that he has the proper documentation if audited. The memo identifies four key issues: 1) the deductibility of jet expenses, 2) required records for personal use valuation, 3) any limits on deductions, and 4) taxable compensation for personal use. It provides brief conclusions but no detailed discussion or citations, as required for the full memo requested in the document.

1. ACC 403 Tax Research Group Project for Summer 2016
Due Date: Wednesday, June 21, 2016.
You may work on this project in groups of 3 or 4 students per
group. (Note that this is a “group” project and not an individual
project.)
Your client (or professor) will not accept a late project (but will
accept it early). Your client (or professor) will not be able to
review your project in advance of its final submission (and
projects submitted early will not be graded in advance of the
due date).
Facts: Juan Alvarez is president of Alvarez Tech Corporation, a
C corporation based in Palm Beach, Florida. He plans to
purchase a new corporate jet that will be used by corporate
officers and other employees to attend business meetings around
the country. He said that too much time is now lost due to the
airport security measures that have been implemented in the last
several years and he believes that he could get a good price on
the aircraft if he purchases it this year.
When the jet is not being used for business trips, it will be made
available to the top four corporate officers for their personal
use. Each of these officers is also a shareholder owning at least
5% of the corporate stock. Juan is looking forward to being able
to fly to Aspen, Colorado on the new jet when he takes his
family there to his favorite ski lodge. Juan wants to make sure
that all of the expenses for the aircraft will be fully deductible
by the corporation. He is aware that the officers may have some
taxable compensation on their personal use of the jet. He wants
to know what type of records he needs to set up to be able to
determine the value of personal travel on the new jet and what
methods are acceptable in determining that valuation. For
example, can the corporation use the cost of a first-class ticket
on a commercial aircraft as the amount that should be taxed to
employees for their personal use?

2. Juan wants to make sure that if the corporation is audited by the
IRS, he will have all of the required documentation. So he needs
your assistance in determining if any limits will be placed on
the company’s deduction for the jet (his wants to maximize the
deduction for the corporation) and how to determine the amount
of taxable compensation to the employees for their personal use
of the job.
Required: Research the above issues for Alvarez Tech
Corporation and prepare a “memo to file” as shown in your
textbook on pages 87-88. Your memo should have four sections:
(1) facts, (2) issues (stated as questions), (3) conclusions (short
answers to each issue), and (4) discussion of your reasoning and
authorities.
When writing the discussion section of your memo, start with
the Internal Revenue Code section, then the Regulation section,
then any relevant IRS rulings or other pronouncements, and
finally any relevant court cases. Please be sure to include
appropriate citations for any primary sources you cite. You can
use secondary authority to assist you in locating primary
authorities, but you cannot cite any secondary authorities in
your memo to file (you must find the appropriate primary
authority and cite only that). You do not need to prepare a client
letter—only the memo to file. Submit one memo per group.
Watch the narrated PowerPoint presentation on how do to tax
research using Checkpoint posted on Blackboard under
Assignments (approximately 34 minutes).
Look under Web Links on Blackboard for a link to Checkpoint.
You can access Checkpoint from anywhere you have an internet
connection but you will need a user name and password to
access it (see user names and passwords next to the link under
Web Links on Blackboard). Only one student can use each user
name at one time (so if you get the message that it is an invalid
user name then it means that someone else is using that
particular user name – so select a different one.) Checkpoint has

3. a topical index that you may find easier to use than doing a
keyword search.
Primary sources of authority that you can cite in your research
memo include:
· Internal Revenue Code
· Regulations
· Court Cases
· Revenue Rulings
· Revenue Procedures
· Private Letter Rulings
· Technical Advice Memoranda
· Actions on Decisions
· IRS Notices
You cannot cite any editorial sources such as explanations,
analysis, annotations, or similar summaries. These editorial
sources may help you locate the above primary sources of
authority, but you can only cite primary sources.
You also cannot cite instructions for tax forms. IRS will not
accept its instructions for tax forms or general publications
(such as IRS Pub. 17) as primary authority because they are
intended only to assist the general public in filling out forms.
These general publications do not go through the same detailed
level of review at a national level as their other pronouncements
listed above under primary sources.
Your professor (or client) will not be able to review your
project in advance of its final submission so please so not ask
the professor if you are on the right track in your research.
ACC 403 Tax Research
Group

4. Project
for
Summer
201
6
Due Date: Wednesday,
June
21
, 201
6
.
You may work on this
project
in groups of 3 or 4 students per group.
(
Note that this
is a “group”
project and not an individual project.)
Your client (or professor)
will not accept a late project (but will accept it early). Your
client (or
professor) will not be able to review your project in advance of
its final submission (and projects
submitted early will not be graded in advance of the due date).
Facts:

5. Juan
Alvar
ez
is president of
Alvarez
Tech
Corporation, a C corporation based in
Palm
Beach
, Florida
. He plans to purchase a new corporate jet that will be used by
corporate officers
and other employees to attend business meetings around the
country. He said that too
much time
is now lost due to the airport security measures that have been
implemented in the last several
years and he believes that he could get a good price on the
aircraft if he purchases it this year.
When the jet is not being used for business trips
, it will be made available to the top four
corporate officers for their personal use.
Each of these officers is also a shareholder ownin
g at
least 5% of the corporate
stock.
Juan
is looking forward to being able to fly to
Aspen

6. , C
olorado
on the new jet wh
en he takes his family there to his
favorite
ski lodge
.
Juan
wants to make sure
that all of the expenses for the aircraft will be fully deductible
by the corporation. He is aware
that the officers may have some taxable compensation on their
personal use of
the jet. He wants
to know what type of records he needs to set up to be able to
determine the value of personal
travel on the new jet and what methods are acceptable in
determining that valuation. For
example, can the corporation use the cost of a first
-
c
lass ticket on a commercial aircraft as the
amount that should be taxed to employees for their personal
use?
Juan
wants to make sure that if the corporation is audited by the IRS,
he will have all of the
required documentation. So he needs your assistance
in determining if any limits will be placed
on the company’s deduction for the jet (

7. his
wants to
maximize the deduction for the
corporation
) and how to determine the amount of taxable compensation to
the employees for
their personal use of the job.
Required:
Research the above issues for
Alvarez
Tech
Corporation and prepare a “memo to
file” as shown in your textbook on page
s
87
-
88
. Your memo should have four sections: (1) facts,
(2) issues (stated as questions), (3) conclusions (short answers
to each
issue), and (4) discussion
of your reasoning and authorities.
When writing the discussion section of your memo, start w
ith the Internal Revenue Code section,
then the R
egulation section, then
any

8. relevant IRS rulings or other pronouncements
,
and finally
any relevant court cases
.
Please be sure to include appropriate citations for any primary
sources
you cite.
You can use secondary authority to assist you in locating
primary authorities, but you
cannot cite any secondary authorities in your memo to file (y
ou must find the appropriate
primary authority and cite only that). You do not need to
prepare a client letter
—
only the memo
to file. Submit one memo per group.
Watch the narrated PowerPoint presentation on how do to tax
research using Checkpoint posted
o
n Blackboard under Assignments (approximately 34 minutes).
ACC 403 Tax Research Group Project for Summer 2016
Due Date: Wednesday, June 21, 2016.
You may work on this project in groups of 3 or 4 students per
group. (Note that this is a “group”
project and not an individual project.)
Your client (or professor) will not accept a late project (but will
accept it early). Your client (or
professor) will not be able to review your project in advance of

9. its final submission (and projects
submitted early will not be graded in advance of the due date).
Facts: Juan Alvarez is president of Alvarez Tech Corporation, a
C corporation based in Palm
Beach, Florida. He plans to purchase a new corporate jet that
will be used by corporate officers
and other employees to attend business meetings around the
country. He said that too much time
is now lost due to the airport security measures that have been
implemented in the last several
years and he believes that he could get a good price on the
aircraft if he purchases it this year.
When the jet is not being used for business trips, it will be made
available to the top four
corporate officers for their personal use. Each of these officers
is also a shareholder owning at
least 5% of the corporate stock. Juan is looking forward to
being able to fly to Aspen, Colorado
on the new jet when he takes his family there to his favorite ski
lodge. Juan wants to make sure
that all of the expenses for the aircraft will be fully deductible
by the corporation. He is aware
that the officers may have some taxable compensation on their
personal use of the jet. He wants
to know what type of records he needs to set up to be able to
determine the value of personal
travel on the new jet and what methods are acceptable in
determining that valuation. For
example, can the corporation use the cost of a first-class ticket
on a commercial aircraft as the
amount that should be taxed to employees for their personal
use?
Juan wants to make sure that if the corporation is audited by the
IRS, he will have all of the
required documentation. So he needs your assistance in
determining if any limits will be placed

10. on the company’s deduction for the jet (his wants to maximize
the deduction for the
corporation) and how to determine the amount of taxable
compensation to the employees for
their personal use of the job.
Required: Research the above issues for Alvarez Tech
Corporation and prepare a “memo to
file” as shown in your textbook on pages 87-88. Your memo
should have four sections: (1) facts,
(2) issues (stated as questions), (3) conclusions (short answers
to each issue), and (4) discussion
of your reasoning and authorities.
When writing the discussion section of your memo, start with
the Internal Revenue Code section,
then the Regulation section, then any relevant IRS rulings or
other pronouncements, and finally
any relevant court cases. Please be sure to include appropriate
citations for any primary sources
you cite. You can use secondary authority to assist you in
locating primary authorities, but you
cannot cite any secondary authorities in your memo to file (you
must find the appropriate
primary authority and cite only that). You do not need to
prepare a client letter—only the memo
to file. Submit one memo per group.
Watch the narrated PowerPoint presentation on how do to tax
research using Checkpoint posted
on Blackboard under Assignments (approximately 34 minutes).
Memo to File
Client: Alvarez Tech Corporation
Subject: Corporate Jet Use
For: ?

11. Researched by:
Date: June 21, 2016
Facts
The president of Alvarez Tech Corporation, Juan Alvarez, plans
to purchase a new corporate jet to be used by corporate officers
and other employees to attend business meetings around the
country. Providing employees the use of a corporate jet reduces
time lost waiting in airport security and allows employees to
conduct work more efficiently. The corporate jet will also be
available to the top four officers for their own personal uses.
All of these officers own at least 5% of the corporate stock.
Issues
1. Will all the expenses for the aircraft be fully deductible by
the corporation?
2. What types of records are needed to determine the value of
the personal travel?
a. What is considered acceptable to determine the valuation of
personal travel?
3. Will there be any limits placed on the company’s deduction
for the jet?
4. What will the amount of taxable compensation be for the
employees that use the jet for personal travel?
Conclusions
1. .
2. .
3. .
4. .

12. Discussion of Reasoning and Authorities
- Generally, section 162(a) allows as a deduction all the
ordinary and necessary expenses paid or incurred during the
taxable year in carrying on any trade or business. Under section
274(a)(1)(A), no deduction is allowed for an activity generally
considered to be entertainment, amusement, or recreation,
unless the taxpayer establishes that the activity is directly
related to or (in certain cases) associated with the active
conduct of the taxpayer’s trade or business.
- Generally, §1.61-21(b)(1) requires an employee to include
in gross income the fair market value of a fringe benefit, such
as an entertainment flight, after subtracting amounts paid, by or
on behalf of the employee, for the fringe benefit, as well as
amounts excluded from income by another section of the Code.
If an employee takes a personal flight on an employer’s aircraft,
and the employer also provides a pilot, the general rule under
§1.61-21(b)(6) is that the fair market value of the flight is equal
to the amount that an individual would have to pay in an arm’s-
length transaction to charter the same or a comparable piloted
aircraft for that period for the same or a comparable flight. If
the employer does not provide a pilot, the general rule under
§1.61-21(b)(7) is that the fair market value of the flight is equal
to the amount that an individual would have to pay in an arm’s-
length transaction to rent a comparable aircraft for that period
in the geographic area in which the aircraft is used. The
regulations do not permit valuation of a flight by reference to
the employer’s costs.
- As an alternative to the general valuation rules just
described, §1.61-21(g) provides that an employee’s personal
flights on an employer’s aircraft may be valued using an
optional special valuation rule, the non-commercial flight
valuation rule. In order to use the non-commercial flight
valuation rule, applying the applicable aircraft multiple from
§1.61-21(g)(7), it is necessary to know the weight of the

13. employer’s aircraft, the number of miles for the flight being
valued, and whether the employee receiving the benefit is a
control employee within the meaning of §1.61-21(g)(8) or (9).
The value of an employee’s personal use of a company aircraft
is computed by multiplying the Standard Industry Fare Level
(SIFL) by the terminal charge to arrive at the value of the flight
(the SIFL formula). SIFL is a cents-per-mile factor that, taken
with the aircraft multiple and the terminal charge, is intended to
approximate coach and first class fares on commercial aircraft.
- Section 274(a)(1)(B) disallows all the expenses, direct and
indirect, associated with the ownership and operation of an
aircraft that is an entertainment facility, except for expenses for
business travel and expenses that meet the exceptions of section
274(e). Thus, expenses for personal, non-entertainment travel
(such as for medical purposes or attending funerals), as well as
for entertainment travel, are disallowed, unless an exception
such as 274(e)(2) applies.
The IRS and Treasury Department believe that Congress, in
adding section 274(e)(2)(B), contemplated entertainment use of
aircraft by specified individuals without specifically
considering circumstances in which aircraft may be regarded as
entertainment facilities. Therefore, these proposed regulations
are limited to use of taxpayer-provided aircraft in entertainment
activities under section 274(a)(1)(A), and do not provide rules
relating to the application of section 274(e)(2)(B) in
circumstances under which aircraft may be regarded as
entertainment facilities under section 274(a)(1)(B). Comments
are requested on whether the IRS and Treasury Department
should issue guidance on aircraft as entertainment facilities and
the content of the guidance.
Memo to File

14. Client: Alvarez Tech Corporation
Subject: Corporate Jet Use
For: ?
Researched by:
Date: June 21, 2016
Facts
The president of Alvarez Tech Corporation, Juan Alvarez, plans
to purchase a new corporate jet
to be used by corporate officers and other employees to attend
business meetings around the
country.
Providing employees the use of a corporate jet reduces time
lost waiting in airport
security and allows employees to conduct work more
efficiently. The corporate jet will also be
available to the top four officers for their own personal uses.
All of these officers own at least
5% of the corporate stock.
Issues
1.
Wi
ll all the expenses for the aircraft be fully deductible by the

15. corporation?
2.
What types of records are needed to determine the value of the
personal travel?
a.
What is considered acceptable to determine the valuation of
personal travel?
3.
Will there be any limi
ts placed on the company’s deduction for the jet?
4.
What will the amount of taxable compensation be for the
employees that use the jet for
personal travel?
Conclusions
1.
.
2.
.
3.

16. .
4.
.
Discussion of Reasoning and Authorities
-
Generally, section 162(a) allows as
a deduction all the ordinary and necessary expenses paid or
incurred
during the taxable year in carrying on any trade or business.
Under section 274(a)(1)(A), no deduction is allowed for
an activity generally considered to be entertainment,
amusement, or r
ecreation, unless the taxpayer establishes that
the activity is directly related to or (in certain cases) associated
with the active conduct of the taxpayer’s trade or
business.
-
Generally, §1.61
-
21(b)(1) requires an employee to include in gross income t
he fair market value of a fringe
benefit, such as an entertainment flight, after subtracting
amounts paid, by or on behalf of the employee, for the
fringe benefit, as well as amounts excluded from income by
another section of the Code. If an employee takes

17. a
personal flight on an employer’s aircraft, and the employer also
provides a pilot, the general rule under §1.61
-
21(b)(6) is that the fair market value of the flight is equal to the
amount that an individual would have to pay in an
Memo to File
Client: Alvarez Tech Corporation
Subject: Corporate Jet Use
For: ?
Researched by:
Date: June 21, 2016
Facts
The president of Alvarez Tech Corporation, Juan Alvarez, plans
to purchase a new corporate jet
to be used by corporate officers and other employees to attend
business meetings around the
country. Providing employees the use of a corporate jet reduces
time lost waiting in airport
security and allows employees to conduct work more
efficiently. The corporate jet will also be
available to the top four officers for their own personal uses.
All of these officers own at least
5% of the corporate stock.
Issues
1. Will all the expenses for the aircraft be fully deductible by
the corporation?
2. What types of records are needed to determine the value of
the personal travel?

18. a. What is considered acceptable to determine the valuation of
personal travel?
3. Will there be any limits placed on the company’s deduction
for the jet?
4. What will the amount of taxable compensation be for the
employees that use the jet for
personal travel?
Conclusions
1. .
2. .
3. .
4. .
Discussion of Reasoning and Authorities
- Generally, section 162(a) allows as a deduction all the
ordinary and necessary expenses paid or incurred
during the taxable year in carrying on any trade or business.
Under section 274(a)(1)(A), no deduction is allowed for
an activity generally considered to be entertainment,
amusement, or recreation, unless the taxpayer establishes that
the activity is directly related to or (in certain cases) associated
with the active conduct of the taxpayer’s trade or
business.
- Generally, §1.61-21(b)(1) requires an employee to include in
gross income the fair market value of a fringe
benefit, such as an entertainment flight, after subtracting
amounts paid, by or on behalf of the employee, for the
fringe benefit, as well as amounts excluded from income by
another section of the Code. If an employee takes a
personal flight on an employer’s aircraft, and the employer also
provides a pilot, the general rule under §1.61-
21(b)(6) is that the fair market value of the flight is equal to the

19. amount that an individual would have to pay in an
Tax Research
2 - ‹#›
Textbook Reading Assignment
Before beginning your research project, please read pages 71-89
and 97-106 in chapter 2 of your textbook.
The sample problem in these slides is the same as the one in
your textbook (starting on page 85)
The sample “memo to file” solution starts on page 87 in your
textbook
2 - ‹#›
Primary Sources of Authority
2 - ‹#›
Legislative Sources
Legislative Sources are also known as Statutory Sources (derive

20. authority from Constitution)
Internal Revenue Code
Committee reports indicate the legislative intent of a bill
House Ways & Means Committee
Senate Finance Committee
Joint Conference Committee
2 - ‹#›
Administrative Sources
of Authority
Interpretations
and specific
applications
of the IRC
Revenue Rulings
Treasury Regulations
Revenue Procedures
Letter Rulings
& other pronouncements
2 - ‹#›

21. Judicial Sources
U. S. Court of
Federal Claims
U. S. Court of
Appeals for
Federal Circuit
U. S.
District
Court
U. S. Court of
Appeals
The
Supreme
Court
U. S. Tax Court
2 - ‹#›
Steps in Research Process
Gather the facts and identify the issues
Locate the sources of authority
Evaluate the relevant authorities
Communicate the recommendations

22. 2 - ‹#›
Locate Authorities
Link to Checkpoint on Blackboard under Web Links
To sign on Checkpoint you will need a user name and password
All of our user names begin with UN12- (note that is UN for
university NOT UM)
We must share user names, so if you get an error message that it
is not a valid user name or password then try another user name
(because someone else is probably using that user name)
2 - ‹#›
Checkpoint
Remember only ONE person can use a user name at a time
2 - ‹#›
Checkpoint Home Screen

23. “My Quick Links” take you to templates for locating authorities
Clicking on “Search” takes you to the Search screen
2 - ‹#›
Search Screen
Left panel allows you to choose method of searching
Middle of screen is used for keyword searching
Table of Contents can for accessed at top
2 - ‹#›
Search by Citation
In left panel of Search screen, select Find by Citation, and then
click on “Code & Regs.”
Enter the Section number in the appropriate box and click on
the [Search] button
2 - ‹#›
Full Text of Code Section

24. Buttons above Code Section can be used to go directly to
related materials. [Expl] for U.S. Tax Reporter editorial
explanations; [Annot] for annotations (summaries of cases &
rulings); [FTC] for Federal Tax Coordinator editorial
explanations; [Regs] for Regulations; [Com Rpts] for
Committee Reports; [Hist] retrieves the history for the Code
section and [New Law Analysis] for recent relevant legislation.
2 - ‹#›
IRS Rulings and other
IRS Pronouncements
To retrieve an IRS Ruling, Procedures, Announcement or other
IRS pronouncement when you know the citation, in the left
panel of the Search screen, under Find by Citation, click on
“Rulings/IRB”
Enter the citation in the appropriate box and click on the
[Search] button.
2 - ‹#›
Court Cases
To retrieve a court case when you know the name or the
citation, under Find by Citation in left panel, click on “Cases”
Enter the name or citation in the appropriate box and click on
the [Search] button.

25. 2 - ‹#›
Using a Topical Index
In left panel of Search screen under GO TO, select “Indexes”
2 - ‹#›
Select Index
Click on the second Index “Code Arranged Annotations &
Explanations (USTR) Topic Index” to locate an editorial
summary of the law along with relevant cases and rulings.
2 - ‹#›
Alphabetical listing
Select the letter of the index to locate your topic.

26. 2 - ‹#›
Facts for Example
Royal Trump, Inc. plans to open a new hotel and casino in
Atlantic City. Royal Trump plans to require its employees to
stay on the business premises during their working hours and
has decided to provide free meals to those employees in an on-
premises employee cafeteria for two reasons. First, if employees
ate off-premises, they would have to go through two security
checks a day (one when they went to lunch and a second one at
the end of their shift). Additionally, there are not a sufficient
number of fast-food eating establishments within a reasonable
distance of the casino that could accommodate the large number
of employees that would flood the area restaurants if they did
not eat on-premises. Royal Trump would like your advice
regarding the correct tax treatment of these cafeteria meals.
2 - ‹#›
Identify the Issues
Identify the issues and state them as questions
Royal Trump’s situation appear to have two separate issues:
Are the meals tax free to employees?
Are the costs of the employee cafeteria deductible by Royal
Trump?
2 - ‹#›

27. Click on Search
2 - ‹#›
Accessing a Topical Index
2 - ‹#›
Code Arranged Annotations & Explanations Topic Index
2 - ‹#›
Look under M for Meals
2 - ‹#›

28. Click on paragraph number
2 - ‹#›
Editorial Explanations
You CANNOT cite explanations (EXP ¶)
Hyperlinks are included to relevant Code sections and other
relevant sources
2 - ‹#›
Follow Links to IRC Section
Sec. 132(e)(2) tells us that certain eating facilities operated by
an employer may be considered de minimis fringe benefits.
2 - ‹#›
Exporting Document
Document tool icons at top of screen allow you to print, export

29. (this is the second icon from the left). Do not attempt to email
because it will only send it to MY email because my email is
the one of record.
Clicking on the Export icon will bring up a popup box allowing
you to select the format for saving the file.
2 - ‹#›
Annotations
2 - ‹#›
Court Case
Scroll down to get to headnote (summary of case)
2 - ‹#›
Headnote
You cannot reach a conclusion based on headnote, but must read
entire case

30. Hyperlinks are included to relevant Code sections and other
authorities
Scroll back up to top of screen and click on Citator
2 - ‹#›
Citator
2 - ‹#›
IRC Sec. 119
Sec. 119 provides for an exclusion from employees’ gross
income when meals are furnished for convenience of employer
on business premises.
Sec. 119(b)(4) says all meals will be treated as furnished for
convenience of employer if qualified meals furnished to more
than half of employees
2 - ‹#›

31. IRC Sec. 274
Sec. 274(n)(1) contains the general 50% limit on deduction but
Sec. 274(n)(2)(B) contains an exception allowing full
deduction.
2 - ‹#›
Searching by
USTR Code Section
In left panel of Search screen, select “USTR Code Section.”
You can also access the USTR template from the Table of
Contents screen by clicking on the link under the Jump To
heading.
Select “Income (USTR),” choose “Current,” and enter the Code
Section number in the box. Click on [Go to USTR] button
2 - ‹#›
USTR Code Section Search
Results include links to the full text of the Code Section, related
committee reports, related Regulations, editorial explanations,
and annotations.
Clicking on the plus (+) displays the next level of documents.

32. 2 - ‹#›
Look at Regulations
Regulations may contains more a detailed description of the
rules, definitions, and examples.
Work your way through the rest of the relevant sources for each
important Code Section.
2 - ‹#›
Keyword Searching
In the Search screen, enter your keyword in the box and check
the sources you wish to search.
Natural language searching lets you use conversational phrasing
to state your question. Terms & Connectors lets you perform a
more advanced search. Click on “Thesaurus/Query Tool” to
select connectors.
2 - ‹#›
Selecting Connectors
Click on the [Spelling] button to check spelling of your
keyword.

33. Add keywords by highlighting the desired connector, clicking
the [Append] button, and entering the additional keyword in the
Current Query box. Click on [OK] button when you are done.
2 - ‹#›
Begin Search
Clicking on the [OK] button returns you to the main Search
screen with your keywords and connectors in the box.
Click on the [Search] button to start your keyword search.
2 - ‹#›
Search Results
Your search results are displayed by source and show the
number of documents that include your keywords.
Click on any of the links to review the documents retrieved.
2 - ‹#›

34. Table of Contents
To browse the table of contents for any editorial or source
materials, click on “Table of Contents” near the top of the
screen.
You can drill down through the content by clicking on the plus
(+) sign to display the next level. Click on the subheading to go
to the full text.
2 - ‹#›
Top Toolbar
Click on “History” to access your recent searches and
documents viewed.
Do not attempt to use “Folders” to save and later retrieve
documents because you are sharing this username with other
students who will access what is in your folder
Click on “Help” to learn more about using Checkpoint features.
When you have finished your research, click on “Sign Out.” Do
NOT just close your browser (because it may not logoff the user
name preventing someone from signing back on right away)
2 - ‹#›
Evaluate Authorities
Consider the following when evaluating the authorities
Internal Revenue Code – read every Code section that is

35. applicable and watch for language that indicates quantities or a
time period
Committee Reports – it is usually best to start with the Joint
Conference Committee report as that will indicate whether the
House or Senate version was enacted
Regulations – check the publication date to see if updated for
latest amendments to the Code
2 - ‹#›
Evaluate Authorities
Revenue rulings – reflect current IRS policy and carry
considerable weight
Letter rulings & notices – carry less weight but are still good
authorities
Court Cases
Tax Court
Federal District Courts
U. S. Court of Federal Claims
Appellate Courts
2 - ‹#›
Evaluating Judicial Authorities
When a case involves a number of issues, the court will decide
each issue separately
The opinion is the court’s statement of the reasons for its
decision

36. Citations for decisions should be checked in a citator to find
out:
The decision’s history
What other courts have said about that case
2 - ‹#›
Evaluating Judicial Authorities
Acquiescence – IRS agrees with a court decision it has lost
IRS issues a nonacquiescence when it disagrees with a decision
A reversal by an appellate court means that the party who won
in the lower court now loses and the other party becomes the
winner on that issue
2 - ‹#›
Communicating Recommendations
Memo to the file usually contains:
Restatement of relevant facts
Issues
Conclusions (one conclusion for each issue)
Discussion of reasoning and authorities (one discussion section
for each issue)

37. 2 - ‹#›
Memo to File
A Memo to File for this sample problem is presented on pages
87-88 of your textbook.
You will be expected to prepare a similar Memo to File for your
research project.
2 - ‹#›
The End
2 - ‹#›