Answer:
The three primary sources of authority that tax professionals should check against the citator before relying on those sources for important matters are;
1. Revenue procedures
2. Revenue rulings
3. Judicial decisions
Explanation:
A citator can be defined as an index of legal resources that allows the researcher to find newer documents of the original document and thus the history of statues and cases can be reconstructed. This has been collectively termed as shepardizing. There are different kinds of citators depending on the type of case one is handling. In our case, we are dealing with tax professionals. Tax professionals deal with three primary sources of authority that tax professionals should check against the citator before relying on those sources for important matters. These primary sources are; revenue procedures, revenue rulings and judicial decisions. They are further elaborated below;
1. Revenue procedures
A revenue procedure is a set of guide that give direction on how to apply law, regulations and rulings. They majorly give direction on matters involving tax.
2. Revenue rulings
A revenue ruling is an order directly from the Internal Revenue Services (IRS) that has the full backing of the law and therefor enforceable. Such rulings on revenue, give direction on how the IRS understands the tax laws. Since the IRS is an authority constituted by top-level tax professionals, a revenue ruling can be used by other tax professionals to cite cases of similar nature.
3. Judicial decisions
Judicial decisions is a statement of advice written by a judge or a panel of judges that serves as a guide in solving a legal dispute. They involve a written legal opinion that tends to justify how and why they arrived to that conclusion to solve the dispute. The same thinking can be used by other professionals in other disputes of a similar nature to solve them.
