Tax practitioners routinely read instructions, revenue procedures, court cases and IRS news releases to stay current, but what weight do these resources have when taking a tax position? Is an IRS Notice or a Revenue Ruling substantial authority? Can you rely on a Summary Opinion of the U.S. Tax Court? How about an unpublished opinion of an U.S. Court of Appeals? How do you determine an Uncertain Tax Position for Schedule UTP? Is that the same standard as ASC 740? Address these questions and more along with explanations of the ins and outs of authority and reliance for tax positions.
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