After you select a topic, let me know what it is before proceeding with Paper. Picking a topic: The topic must involve federal tax law.
It can be a topic involving income taxes or gift or estate taxes. It must be a topic that is currently relevant – a topic that is primarily of historical significance is not appropriate. If, for example, your topic involves a particular code provision, be certain the provision has not been substantially revised – are the authorities pursuant to the current language? The topic must have AT LEAST 25 major (significant) cases or rulings. Major (significant) means that the case or ruling adds something to the body of law on the topic. A minor case or ruling is one that largely or entirely duplicates the facts and law of another case or ruling.
You should carefully note that this is how major (significant) and minor are defined for purposes of this project – these definitions may differ from more common use of the terms – in particular, these definitions have a much lower threshold for what is considered major (significant). I think one may naturally ask, why should there be a case if there is not something different about the case from prior cases – why bring the case?
There may be an explanation (e.g., the case was brought for issues primarily not related to your topic and the party threw in your issue because there was little to lose in doing so), but generally a new case adds something to the topic. Also, for example, a PLR may or may not be major – some PLRs are sought even though the issues are relatively well settled (e.g., so-called comfort rulings).
While your topic can involve code or regulation analysis (and must include coverage of relevant code or regulation provisions), it generally should be a topic that is primarily driven by cases and rulings.
You can use the Checkpoint legal database to conduct your research (or any other legal database to which you have access). The URL is www.checkpoint.riag.com the username is pac88-4 and the password is also pac88-4. EVERY
