 Hello and welcome to the session in which we would look at federal tax authority. Specifically, we're going to be looking at the three sources of tax authority, discuss these parties, discuss their roles as they relate to federal tax authority. This topic is covered in an income tax course graduate or undergraduate level, the CPA exam, as well as the enrolled agent exam. Therefore, if you are a CPA candidate or a tax accounting students, I strongly suggest you check out my website farhatlectures.com. I don't replace your CPA review course. I don't intend to do so. I can I cannot do so, but I can be a useful addition to your CPA review course. I can add 10 to 15 points to your CPA exam so you can pass, move on and focus on your career. Your risk is one month of subscription. Your gain is potentially passing the exam. Are you willing to take that risk? And if not for anything, check out my website to find out how well or not well your your university doing on the CPA exam. I do have resources for other accounting, tax finance and other courses. Please connect with me on LinkedIn and check out my LinkedIn recommendation, like this recording, share it, follow me on Instagram and Facebook. So the first thing is we want to know it is a definition that's called because you know we want to know what is what is a substantial tax authority. A substantial tax authority is what is the authority. It's the sources that's going to tell us whether an item is taxable, deductible, includeable, executable from income, so on and so forth. So what is the tax authority? What's the source of it? Well there are three sources of tax authority. There are legislative law, administrative law and judicial law. And guess what? Since I have a list, I'm going to go over each one of these sections separately. And before we look at the judicial law, we're going to look at the audit process so we can tie it to the judicial law. Starting with the legislative law. Hopefully we all know what that when you think of the legislative law is basically the Congress, right? Legislative law, that's exactly what it is, part of it. So the legislative law is the law itself. It's the original source in contrast to the administrative and judicial, which we're going to see later, which are interpretation of the law, of the legislative law. So who who writes the legislative law? U.S. Congress, okay? Like for example, the Tax Cuts and Jobs Act was written by the Congress. Also, what's considered legislative law if the Congress issue any tax treaties, which is an agreement with another country between the U.S. and a foreign country. And the reason for it is to govern income, income earned in foreign countries. Therefore, we avoid double taxation, okay? Internal revenue code. The internal revenue code also is a legislative law because it's simply put coming from the U.S. government itself. It's a primary source of federal tax law. And hopefully you know this, the internal revenue code can impose on you all sorts of taxes, income tax, state tax, employment, excise tax, so on and so forth. Now we have something called Congressional Committee Report. Now, what is the Congressional Committee Report? Well, it sounds like something to do with U.S. Congress because congressional, it is something to do with the U.S. Congress, okay? Because when the U.S. Congress writes a law or sometime the language is ambiguous and when the law is initially published, it may not confuse, but some people may think there's a conflicting information in it. So what's going to happen? The Congress will issue this congressional committee report for what? To clarify the law. To determine the congressional intent. The keyword is intent. The intent that's behind the tax law. Therefore, people, not people, preparers, CPA lawyers, they know how to apply the law properly, okay? So basically, it gives you the reason behind the law and it helps you apply it, how to apply it. And obviously, the U.S. Constitution in theory is a legislative law, but usually the U.S. Constitution don't deal with tax law. So those are sources of legislative law. Let's move on to administrative law. And when you think of administrative law, think of the Department of Treasury, okay? Administrative tax laws are rules, regulations and procedures implemented and enforced by the Treasury Department. Now the IRS is a bureau of the Treasury Department. So the IRS comes underneath the Treasury Department. And when it comes to administrative law, we're going to look at seven things, I believe. Treasury regulation, revenue ruling, revenue procedures, private letter ruling, PLR, internal revenue bulletin, technical advice memoranda and IRS publication, seven, seven items. We're going to look at each one of these items separately, fairly quickly, but you need to be familiar with them on the exam. I'll try to make sense of them as much as possible, but that's the nature of the beast. It's basically a law you just have to know to memorize it at some point. Starting with the Treasury regulation, those are the official interpretation of specific code law. It's simply Treasury regulations are the highest administrative authorities issued by the Treasury Department, okay? Now bear in mind, the IRS is bound by these regulations because remember, the IRS is part of the Treasury. So of course, they are bound also court, accept them as long as they don't conflict with any other IRS regulation. Simply put, Treasury regulations are simple language, detail and relevant practical guidance. That's all where it is interpretation of the law. Revenue ruling, okay? And they are primary authority, primary authoritative source when conducting tax research and we'll look at that later. Revenue ruling, they're issued by the IRS, okay? Like regulation provide interpretation, but they don't. They do not have the force or bind the court by them. So they don't have the force of a regulation, okay? So although they are interpretation, but they are not as powerful as Treasury regulation because they provide a difference between revenue ruling and Treasury regulation. Rulings, they provide examples, an example or two about how the IRS will apply the law against a specific case. The regulation is basically an umbrella of rules. Like it tells you in most situations, this is what you use. Revenue ruling is looking for a specific case. So it gives you an example or two. Again, it's published by the internal revenue bulletin. We'll talk about internal revenue bulletin later on to inform and advise taxpayers, the IRS and other substantive tax issues. It's intended to promote the purpose of the revenue ruling uniform application of tax law by IRS employees and to reduce the number of letter ruling requests. So simply put, look, if you're seeing this case again and again and again, here's the answer for it. Here's the revenue ruling. Just let's use it and get done with it, okay? And to reduce something called the number of letter ruling requests. Now we're going to see what letter ruling request. So something will happen because we have too many letter ruling requests will issue revenue ruling because we're getting the same question again and again about the same topic. Well, let's issue a ruling and say this is how it should be done with and it becomes a revenue ruling. And we're going to see the difference between revenue ruling and letter ruling. So deal with common fact pattern. When we see there's a pattern, same questions coming up again and again. Let's give some specific guidance this way. When we get this question, we have an answer for it immediately. That's what revenue ruling is. It's also a primary authoritative source when conducting tax research. Revenue procedures are a little bit different. It deals with the internal management practices and procedures of the IRS. Now here we're dealing with like kind of not logistics but like red tape, red tape. For example, how to request a letter ruling, how to request a letter ruling, okay? So failure to follow revenue procedures, how to do it, it may delay the process, okay? It doesn't have, revenue procedures don't have the force of the law. Basically it's how the IRS run the administrations themselves. These are the laws you have to follow. You have to fill out this form, make sure it's signed, so on and so forth, okay? Now private letter ruling. So we're talking about letter ruling. It's specifically, it's a private letter ruling. PLR, you may see it in your textbook or in your review course. Here's how it is. You pay a fee to the IRS to ask the IRS how would you treat this proposed transaction. So it's a proposed transaction. It didn't happen yet but you just want kind of an advice or from the IRS. Therefore what you do is you issue, you ask them, look, could you please tell me how would I, how would I deal with this situation? Now if this same situation kept on coming with like how to treat stock options for example, which is really an old issue, or how to treat for example cryptocurrency transaction, okay? Something new, okay? If that questions kept coming again and again and a private letter rulings, people are asking, they're paying money for it, the IRS would say, oh there's a common pattern here. Let's issue a revenue ruling to give them the answer. Now if it's a private letter rulings, it only binds when they give you the answer. It binds you, the person that made the request and the IRS, okay? No other party can rely on it. Do not bind third party nor it can be used as precedent. Now although it cannot be used as precedent, but you can look at it for guidance, if you ask the question, they should give you the same answer. What the IRS does, they respond to multiple private letter ruling requests by issuing a revenue ruling. In this way, once we issue the revenue ruling, it binds all taxpayers and the IRS. Basically it becomes the rule because we see this issue coming back again and again. They just issue a rule this way. Everybody knows about it. Then we publish it and everybody will see it. We no longer get those same questions, okay? Where do we publish it? We can publish it in the Internal Revenue Bulletin. It's a weekly publication of the U.S. Revenue Service that announces official rulings and procedures of the IRS in publishing the Treasury Decision Executive Order Sex Convention. Basically anything the IRS wants you to know, what's going on in the Treasury Department, any court decisions, they will issue it in this Internal Revenue Bulletin. Now we have something called Technical Advice Memoranda or TAMS. Those are similar to letter ruling or the PLR, but deal with completed, not proposed. Now the transaction has been completed. It's in front of an IRS agent. They're looking at it and they don't know what to do. So it's issued to IRS field agent or questions rate by the taxpayer. Now it's not proposed. It's a completed transaction. So you will send your request to the National IRS Office and you'll ask them, could you please tell me what should I do in this situation? It cannot be cited as a precedent, okay? So basically it's again like a letter ruling because either the taxpayer doesn't know how to deal with this. They already completed the transaction nor the IRS agent who's handling, who's investigating. Therefore they need a little bit more help. Well, the National Office will issue them this TAM. Also we have the IRS publication. I hope you are familiar with IRS publication because in my tax course, I oftentimes, I ask my students to use them somehow in completing a, in completing the tax forms or completing a tax project. So you should be familiar with them, POP17, I hope so. Explain the law and plain language for taxpayer. A lot of people think it's not really plain language but they think it's a plain language. It highlight any changes in the law and provide examples illustrating different scenarios. It's a good source of information but it cannot be cited to sustain and position it, okay? So those are the administrative law, the seven items that compose administrative law. The next thing we're going to look at is judicial law. And when you think of judicial law, think of the court system, judges, okay? It's originate from the federal court system, the common law. It's primarily composed of court opinion. Court cases are considered a primary authoritative source when conducting tax research, okay? But before we discuss the judicial law, we want to know how do we get to the court system? So we're not going to just kind of jump, we file our return, we disagree with the IRS or the IRS they disagree with us. So we go to the court. It doesn't happen this way, okay? So let's go through the process. This way it's easier to understand the big picture. Let's discuss the audit process. So remember in the U.S., if you're not aware of this, if you're someone who's outside the U.S., in the U.S., the tax system is self-assessed and self-reported. Simply put, the IRS doesn't, you know, send us a bill every year. This is your tax. We prepare our taxes and we tell the IRS, this is how much we need to pay in taxes. Well, guess what? Uncle Sam is not, you know, is not stupid nor Congress to trust us. So when they do some time, they audit us. They audit, you know, because the process is an voluntary process, especially voluntary in quote. It's not voluntary. You have to pay your taxes, but it's self-reporting, voluntary in that sense. So what they do as an enforcement, they can audit you. You can be selected to be audited for many reasons, okay? So what techniques would the IRS use to select your audit? One thing you can randomly select it, that tough luck, that's your chance, okay? So someone will select your case and guess what you are selected for audit. Now, for example, President Trump, he was selected for audit. No one knows whether it's manual, somebody selected it, or for other reasons, but that's way before he was president. Nevertheless, it's always a political issue. And I remember when President, is it when President Obama was an officer, it was a big deal about auditing a nonprofit organization. I believe it was funding the Republican Party. You know, my memory here is very fuzzy. And it was the same thing that, you know, it was politically motivated. The nonprofit was selected, you know, for political reasons, okay? So it can be randomly selected. And this is the worst thing. If somebody is targeting you, especially as government, you really don't want that, right? That's the last thing you want on your shoulders, okay? Or you can be selected statistically. The IRS, they have a software called Discriminate Inventory Function System or DEF. It basically, because they have so much data about the taxpayers and various returns, they know they should be able to predict what type of returns, what type of return profile they should have errors. It's not only what type of return they have errors. And they want the error to be in their favor. Then if they audit you, they spend time because the IRS don't want to audit you. If at the end of the day, they want to pay you back the money. If they want to audit you, they want the money. The US government wants your money. It's not the other way around. So the, so somehow they have a system that can determine whether this return has errors or not. And after that, it's going to be in our favor. What could be some statistical, some statistical indication? I mean, I'm just trying to give you an example that, you know, for example, if you have too many expenses in relationship to sales, for example, too much advertising or consulting expense in relationship to sales, and based on your business, because every business has a code based on that code, that's a high percentage. For example, that could be an indication that you either spending too much money or, or simply put, you are expensing stuff that you're not supposed to be expensing there. Okay, so there's an error. Now, obviously, they don't tell you what the system is. Otherwise, if they tell you, then businesses will be very careful. But sometimes they do provide other data that could help you, which we'll see in a moment, avoid being audited. Okay, but that deaf system, they could use to do that prior history with the IRS. If you were audited before, and obviously, if they found an error, there's a good chance they might audit you again. So it increases your chances of being reselected if you were audited before. If there's any discrepancy in what's reported to the IRS and your information, a good example will be your W2. For example, your W2 shows you should have 100,000 in earnings. You only reported 80,000 because your W2, your employer, sends the information to the IRS. The employer tells the IRS, this is how much we paid Mansour, 100,000. If you reported 80,000, and that, and by the way, all this information is automatic. And the reason I can comfortably say this, because I had my experience with this, I know my cousin, like when I was practicing, I completed his taxes. And I still remember, I transposed two numbers. I don't remember three and four, like his salary was, I don't know, $45,000, $34,000. I put $45,000, $34,000 instead of $43,000. And it triggered a discrepancy that, because it was all electronic, it's basically, his employer says he was paid this much. I'm showing them the return he was paid that much, and they don't match. It created a, there was a discrepancy. So because of this discrepancy, you can be audited. And the, too much itemized deduction, that's an obvious reason. If you have too much itemized deduction, like your taxes, it's not an issue anymore, because you're limited, if you have too much interest or charitable contribution, you might be selected. You might be selected because the IRS, they have millions, literally millions and hundreds of millions of taxes. And over the years, they have maybe billions of taxes. And they know on average how much the average US individual, if somebody's making $80,000, they usually contribute this much. If somebody's making $200,000, they usually contribute this much. They have a data for millions of people. Therefore, if one person is showing too much, too many itemized deduction, it doesn't mean they're committing fraud, but it's going to raise the IRS. It's going to raise flak with the IRS. Now, TurboTax warns you. For example, TurboTax, they'll tell you when you are preparing your taxes. Well, based on your income, this is what the average itemized deduction should be or charitable contribution, because that data is the IRS published it on, published it on a regular basis. Types of audit. What happened if you are audited? Okay, there's, you could be audited by mail or you could have a formal examination. Let's talk about both audited by mail. Simply put, this is not a big deal. Simply put, actually, I was audited by mail once in my lifetime. And that was in the year 2000. I still remember. And the reason I was audited by mail is simple, because again, audited by mail is when you're informed, you're reported and what somebody else reported, there's a discrepancy. I used to work with Merrill Lynch. So I'll tell you the story. It's funny. It's not funny, but well, it's sad, funny, but it's funny. So I was very immature. That was the year I graduated. So that year 2000, 2001, actually it was 2001, because I didn't get my bonus till 2001. So in 2001, I was, I was working in the stock market with Merrill Lynch. I get my bonus for that year. I was very happy. I invested everything in the stock market. And guess what? The stock market crashed and I lost all my money. Now, back then I was really, I did not know the law that much, the tax law. And I decided to do my taxes. So I know that you can deduct up to 3000 of capital losses. And back then you had to input everything. Now you input all this data electronically. You just log into your system, you know, like into your shard swab or fidelity and it will transfer everything to your income tax. Back then what you had to do is you had to input every transaction manually. I'm talking about 2000, 2001. So as you know, I knew I can only deduct up to $3,000 in capital losses. I had more than $3,000. So what I did is I kept importing transactions until I reached $3,000 and I stopped. I said, okay, because the remainder, I will take in 2000, 2003, whatever remained, I will take it later, okay, against my future capital gain. But what happened back then, Merrill Lynch, which is my broker, when they send, when they send the information to the IRS, they only send the proceeds. In other words, they show proceeds, for example, let's assume they showed $50,000 of proceeds. Just I don't remember the number is, I'm not sure of whatever it was. Let's assume they showed 50,000 on my tax return, I was showing, for example, only 5,000. The reason I was showing like or 10,000. The reason I was showing only 10,000, because 10,000 minus 7 is 3,000 of losses. So all I wanted to show is 3,000 of losses. And I didn't really want to compute all of my losses. I was pretty angry with myself. So I said, well, I will do it later next year since I can, I can do this in the future year. So what they did, I was audited by mail. And basically they told me, I owe this additional money. So I said, not really, I have additional losses. Therefore what I had to do, I had to fill out my schedule D, my complete schedule D, send it to them. And I believe that was in 2000, 2000. They didn't cut up with me until 2003, but they eventually cut up with me. I was not trying to hide anything. I had the losses, simply I did not report them. And Merrill Lynch was showing I have more money than my costs. So that's all what it was. So it's not a big deal. Okay. It could be happen, you know, it doesn't match. Again, transposing numbers that what happened with my cousin, that could be a reason, information errors, the social security don't match or something like that. So this is corresponding by me. It's not a big deal. We send you the notice, pay it, or if there's any problem, fix it and send us send us the work paper. Okay. Now you could also have a formal examination. This is called the visitation audit. And they could visit you at your office. Oh, I'm sorry. It could happen at the Rosso office. They could invite you bring your paperwork and let's do the audit, or they can have a field office. They can come to you and audit you either at your business, your home, at your CPA firm or the paper is paperwork is or with at your attorneys. Now, if the issue is resolved by the revenue agent, that's good. If the IRS agent, they come to your home, to your business, to your CPA and they look at the paperwork and you provide an explanation and they are satisfied with it and you'll pay money and you move on with your life. You sign something called form 870 waiver of restriction on assessment and collection of deficiency and tax simply put, you'd say, okay, the IRS agent, here's the IRS agent, they would say, okay, you owe us an additional 630,000. And maybe some of you are laughing now because you know what I'm talking about. Why am I saying this? Because if you watch Breaking Bad, this is what happened when Skyler, she acted dumb. She was the bookkeeper for Ted. If you watch the show and they were audited and Skyler acted as if she did not know what she was doing acted like dumb and the IRS agent gave him a break said, okay, you owe us the money. We're not going to proceed any further, pay the money because of your bookkeeper is not competent. And if you watch the show, it's really nice, nice show, really Breaking Bad, I like the show I watched it like maybe three times already. Yes, so Skyler, she acted dumb and she got head of the hook, but you know, they had issues later on. But yes, so that's what happened. They signed form 870, you pay your bill. And if they owe you money, they'll give you the money. But if you owe, you have to pay the taxes plus interest. And if you watch the show, Ted decided not to pay, then Skyler had to resort to Sol, Sol sent him his 18 to force him to pay. Ted had an accident, and you can watch the show yourself. Yes, so that's what it is. It was a field audit. And basically, Ted agreed to form 870, but he did not want to pay. So once you agree, you have to pay. So what happened if the issue is not resolved? If the revenue agent, you and the revenue agent did not resolve the issue, what they do, the revenue agent will give you a 30-day letter. And they would say, okay, you have 30 days to conduct an administrative appeal. Okay, you're not in court yet, and you conduct this administrative appeal with an officer, basically. Okay, so you go to the office of appeals, not the court yet, to resolve this issue before going to court. So once after the revenue agent is done, or the IRS agent, there is the administrative officer. If you can resolve the issue there, that's great. If you can resolve the issue with them, well, that's good. You will sign an 870 AD. You guessed 870 administrative with the administrative appeal. You resolve it. It's binding to all parties. You pay your bill just like 870 would have been binding if it was agreed with the revenue agent. So after the revenue agent, you have the administrative appeal. Okay, it's binding for everyone and it's done. If the issue is not resolved, you still, you know, you and the IRS are still in disagreement, they'll give you 90 days to pay the deficiency. Now you have notice of deficiency to pay, or you can file, listen to me carefully, with the US court. If you don't pay, if you don't want to pay, you can file with the US court. If you want to file with any other court, other than the US court, you have to pay. Without paying the bill, you can only file with the US tax court. We're going to discuss this in a moment. So the notice of this notice of deficiency would say, okay, now I'm going to go through the court system. Now you're going to go through the court system. Okay, to file another court, you need to pay the bill first. So remember the only place where you can, I'm going to repeat this several times. The only place you can file a case is in the US court without paying your bill. You're going to get sick of me the next five minutes saying the same thing. Okay, so here's how the court system looks like, our court system. So first you start at the lower court. What are the lower court? We have the US tax court. We have the US district court and we have the US court of federal claims. Okay, those are the three courts and we're going to discuss each one of them separately. This is where you start. Well, if you don't like the decision, you can appeal. For the first two court, the US tax court and the US district court, you would appear to the US court of appeals, there's 12 of them. For the US court of federal claims, you would appeal to the US court of appeals federal circuit. So this is what happened. Okay, then if you are not happy with these appellant courts, what you can do is you can appeal to the Supreme Court, sell them, not sell them rarely or the US Supreme Court will hear a tax case. I mean, many cases are appeal to the US Supreme Court, but the US Supreme Court, they don't have time for all these cases because they have so many other issues, they sell them. They sell them here at tax courts, but this is just showing you how it works. If the Supreme Court declined to accept it, then guess what? Then whatever the US court of appeals decided will go with that decision. It doesn't mean the US Supreme Court agrees with that decision, just simply the US Supreme Court don't have time to look into it. Okay, so the appellant decision holds. Now, if the IRS decided to listen to the case, it will issue a writ of, here's my writ of cert or writ of certiori, certiori. Well, my Latin is not that good and they will accept the court and they would look into it. So this is the overall picture. So most civil tax cases, in most civil tax cases, the taxpayer has the burden of proof, which is, and it doesn't have to be unreasonable of doubt, they have to show preponderance of evidence, which is more than 50%, more than 50% chance that they are right. Now, we're going to discuss each of these courts separately, advantages and disadvantages, why would you file in one and not the other. Basically, we kind of knew why we would file in the US tax court, starting with the US tax court. As the name suggests, look, sometimes the name would reveal itself, US tax court. And guess what? It only handles what type of cases? Tax cases, you got it, easy to remember, US tax court. Just look at the name. And the good thing about the US tax court, you don't have to pay the file. So you can file, say, you know, I disagree, I'm going to file, and I'm not going to pay yet until the court is done. There's no jury in this court. So the judge, maybe an expert, the CPA, former CPA, or a judge that has, you know, some type of PhD or a master's in taxation will hear your case. They do have a small cases division, basically, they do have a small cases division, like a different division. And if you accept to go there, there's no appeal, whether you lose or you win, it's done, it's a final decision. Okay. Now, the US tax court have to issue two type of decision, and you need to be familiar with them. One is a regular decision. Regular decision means that decision, it's a new case where a new precedent is established. Remember, our tax, our court system, once they decide a case, and it's a new case, it becomes a precedent, it becomes the law. If it's a new case, it's called a regular decision. And that's important. That's a big thing. If you win a case, it means you basically changed the law. Now the law is your case. Everybody's going to look at your case as a precedent. If it's not a new precedent, it's called a memorandum. Basically, the judge applied existing law or existing precedents, and it has little value as far as tax law is concerned, because it already existed. All what the judge did is apply the existing law. So this is the US tax court. Again, if you're not happy with their decision, you can go to the US court of appeals, US court of appeals, the regional circuit, which is 12 of them. Or you can start your decision with the US district court. Here you can have both civil and criminal cases, you're not limited to taxes. Notice, because US tax court is limited to taxes. Okay. There's one court per state, at least remember, it's a district. Look at the name of it, district court. I think it's a location. So each state will have at least one. Some states will have more. Okay. Simply put, because it has to do with the jurisdiction, the district of where you are operating or living. You could either choose a jury or a judge to oversee the case. You'll have to pay your bill first here. And this is the disadvantage. You have to pay your bill. And sometimes those are millions and millions of dollars. Okay. The third court is the court. And again, if you're not happy with the US district court, you will go the regional circuit, which is US court of appeals. Notice the regional, just like here's the tax, and the district goes to the regional court of appeals. The US court of federal claims, this court will hear any claim for money against the United States. Okay. It's located across the whole country. It's the US court of federal. So it could be anywhere in the country. There are 16 judges. Okay. Here your judge will, your lawyer will have to select what's the best court to file because they have to use their judgment basically, their skills. There's no jury. So basically a judge will decide and there are 16 of them. And I'm not sure if you follow the news, but President Trump basically appointed any and every judge he could have in those court system. No jury. And you have to pay your bill first as well. So you need to know the difference between those courts. Just know that US court of federal claims, if you're not happy with the decision, it goes to the US court of appeals, the federal section of it. Okay. Also, we need to know the hierarchy of authority because notice we have so many different authorities here of tax authorities. So let's go through them in a hierarchy, hierarchical perspective. The highest authority is the US Constitution, which is we don't, you just don't worry about this because it doesn't deal directly with taxes. Next comes IRS or internal revenue code in the United States Supreme Court. Again, also think of the Supreme Court, they really don't, they get don't, they don't get involved with tax issues. But in theory, they can, if the cases appeal to them, and they accepted the case, remember RIT of cert, they will accept it and they will look into it. And if they make a decision, the decision will becomes the highest authority. Okay. Now let's assume, let's for the sake of some sake of illustration, if there is a case where it appeared with the US Supreme Court. So yeah, now you have US Supreme Court decision, IRS decision. Well, which one is the latest? Most probably it's the US Supreme Court will override the internal revenue code. Then comes the Treasury Regulation and Appellant Court opinion, same concept, same concept. If you have both the latest decision, if the court opinion is the latest decision that will override the Treasury Regulation, if the Treasury Regulation is the latest decision, it will override the Appellant Court opinion. Then we have the US Tax Court, US District Court and the Federal Claims Court. Okay, there are, again, in hierarchy, we're going down, we're going down the hierarchy. So any decision by the Treasury Regulation would override those court. Any decision by the court of Appellant Court would override those courts. The US District Court, the Federal Claims and the US Court. Then we have the revenue rulings, which we talked about and revenue procedures. And at the end, private letter rulings and others. So notice, when you are on the same level, the latest one in times of one was at issued last is with override. So revenue rulings would override revenue procedures if they are discussing an issue and it's in both. But if the revenue rulings came last, it will override it and same thing with revenue procedures. And basically, this is all what I'm going to go over in this session. That's basically just knowing what parties are involved, the roles, what are they responsible for, what type of rules they can issue. That's basically what it comes down to. If you're studying for your CPA exam, again, I'm going to invite you to check out my website, farhatlectures.com. I do have my lectures, my resources aligned with your CPA review course. So it's easy to follow. Again, I don't replace your course. I can be useful edition. I can attend the 15 points to your CPA exam by helping you understand the material differently than your CPA review course. Your risk is one month of subscription. Your gain is potentially passing the exam. Be confident, study hard, stay safe.