Case brief (federal tax)

1) What are the basic differences between IRS regulations, revenue rulings, and private letter rulings?

2) How is the Internal Revenue Code organized, and what are some reasons why understanding the organization of the Internal Revenue Code may prove useful?

3) In writing a tax court case brief, what is the FICA model of analysis, and what information should be presented in each of the sections on Facts, Issue, Conclusion, and Analysis (sometimes referred to as Facts, Issue, Holding and Rationale)?

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