TAX-670 addresses a genuine practical reality of tax practice: not every tax question has an obvious, clearly stated answer in a textbook, and professionals need a systematic research methodology to work through the Internal Revenue Code, regulations, case law, and administrative guidance to reach a defensible conclusion.
The tax research process
The course covers a structured research methodology — identifying the precise tax issue, locating relevant primary sources (the IRC, regulations, case law, rulings), and synthesizing them into a defensible conclusion.
Navigating primary source hierarchy
TAX-670 covers understanding the hierarchy and authority of different tax sources, since not all guidance carries equal weight, and knowing which source should control when different guidance appears to conflict is itself a genuine research skill.
Key topics in TAX670
- Structured tax research methodology
- Identifying the precise tax issue
- Locating and using primary tax sources
- The Internal Revenue Code, regulations, and case law
- Understanding the hierarchy of tax authority
- Synthesizing research into a defensible conclusion
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Worked example: resolving conflicting-seeming guidance
- Situation: Two different sources appear to suggest different tax treatments for the same situation
- Research methodology: Determining each source's actual authority level and how they genuinely relate (one may simply not apply to this specific fact pattern)
- Lesson: TAX-670 teaches that skilled tax research resolves apparent conflicts by correctly understanding source hierarchy and applicability, not by picking whichever answer seems most convenient
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Frequently asked questions
Many real tax questions don't have a single, clearly stated answer readily available — the applicable rule might depend on how several provisions of the Internal Revenue Code interact, on relevant case law interpreting an ambiguous statute, or on administrative guidance that only partially addresses the specific situation — and a systematic methodology is what allows a professional to work through this genuinely ambiguous territory reliably rather than guessing or stopping at the first source found. TAX-670 teaches this methodology because tax research is a distinct, learnable skill separate from simply knowing tax rules that are already settled and clear.
Not every tax source carries equal legal weight — the Internal Revenue Code itself, Treasury regulations, court decisions, and IRS administrative guidance like revenue rulings each have different levels of authority, and apparent conflicts between sources are often resolved by correctly understanding which source actually controls for a specific situation, or by recognizing that one source simply doesn't apply to the particular facts at hand. TAX-670 covers this hierarchy because a tax professional who doesn't understand it risks reaching an incorrect conclusion by giving equal weight to sources that genuinely carry different levels of authority.