Obviously, the most basic reason for someone in our profession to do in-depth research is to complete the tax return. But that isn’t the only thing we need to do with our material. If you are taking a position from one of the lower standards in Part 2 of our series you may need to cite your research material on an IRS Form 8275, Disclosure Statement. This is the IRS form to use when you need to explain why you did something on a return that may not make sense to someone without the details. You need to lay out you case for the deviation and then include your citations for the authority to do so.
That isn’t your only use for the research you have done. If you are assisting a client with an IRS letter or audit you may need to quote your citations. Make sure you use IRS titles for the citations. Instead of putting IRC XXX.XX(x) put Cod. Sec. XXX.XX(x). When using citations you should drill down to the most relevant paragraph in your correspondence as well. Instead of putting Cod. Sec. 162, which is approximately 14 pages long, use Cod. Sec. 162(g)(1).
Some of the things you will use as citations frequently should be identified as follows: Read More