[REG] FED LEG

Process

 

 

Primary authoritative sources

- provisions of the Internal Revenue Code, statutory provisions

- Treasury Regulations

- IRS rulings( revenue rulings, revenue procedures, explanations of such treaties)

- Court cases

 

 

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Appeals process

 

 1) Agreement not reached at revenue agent level > copy of revenue agent's report + 30day letter

> Request an administrative appeal with an appeal officer(appeals conference)

 

2) Office of Appeals,

- goal is to resolve disputes without litigation

- agreement not reached > 90 day letter

 

* US District court 배심원 하나

* US supreme court 배심원 없음, 판사만 9명

* if taxpayer loses a case in the small cases division of the US tax court, after 90days letter > not appealable

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Civil case - Burden of proof on the plaintiff, the preponderance of the evidence

Criminal case- Burden of proof on the IRS, beyond reasonable doubt