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What is the difference between primary and secondary authorities? Explain the role of each authority type in conducting tax research.

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Final answer:

Primary authorities are official legal documents that impact tax decisions, while secondary authorities offer interpretations and analyses. Both types of authorities operate together to form a basis for tax research, with primary authorities providing the legal framework and secondary authorities aiding understanding.

Step-by-step explanation:

The difference between primary and secondary authorities pertains to their roles and how they're used in tax research. Primary authority refers to the set of official, legal documents that have binding effects on tax decisions. This includes the Internal Revenue Code (IRC), treasury regulations, court decisions, and other official pronouncements. Secondary authority, on the other hand, refers to non-official interpretations and analyses of tax law. These can include tax journals, law review articles, and treatises. While secondary authorities are influential and can guide understanding, they do not hold legal sway like primary authorities do.

The role of primary authority in tax research is to serve as the legal basis upon which tax professionals make arguments and decisions, as they offer the official rules and applications of tax laws. Secondary authorities play a complementary role, providing interpretation, commentary, and insight to better understand complex tax issues and argue cases effectively based on expert opinions.

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