A finished ACC-460 Topic 1 tax authority ranking memo example, sorting six sources on a hobby question into binding authority, persuasive authority and research aids, with a reason for each placement. Searches like "acc 460 topic 1 assignment example", "acc460 topic 1 sample" and "acc-460 topic 1 example" land here.
What a finished ACC-460 Topic 1 tax authority ranking memo looks like
The finished memo is addressed to a tax manager and runs to about two pages. Its first table lists the six sources already in the file: section 183 of the Internal Revenue Code, the Treasury regulation under it that sets out nine profit-motive factors, a revenue ruling, two court decisions from different forums, an IRS publication and a tax blog post. Each row gives the issuing body, the level it sits at and whether it binds the IRS, the taxpayer or a court. The memo then explains the ordering in prose: the statute controls, a final regulation carries the force of law unless it departs from the statute, and a publication is guidance a preparer may read but cannot rely on. The blog post survives only as a pointer to primary sources. The hobby question itself is left open.
How an ACC-460 Topic 1 example is structured
The memo is organized from the question, to the ranking, to what the ranking permits. A two-sentence statement of the question comes first, with the facts cut down to what decides which sources matter. The source table follows, one row per item, giving its citation form, its issuer and its weight. Next comes a paragraph on the statute and the regulation, noting that the regulation interprets section 183 and is read against its text rather than in place of it. A paragraph on administrative guidance separates the revenue ruling, which the IRS treats as binding on itself, from the publication, which it does not. The court decisions are placed after that, with a note that a Tax Court decision is weighed against the circuit to which an appeal would go. The final paragraph lists which sources the eventual answer will cite and which it will leave out.
Six sources sorted before reading
The memo ranks every item in the file by the body that issued it and the force it carries, before any of them is read for an answer.
Statute above the regulation interpreting it
Section 183 governs the question, and the regulation's nine profit-motive factors are presented as the Treasury's reading of that section rather than as a separate rule.
Rulings and publications kept apart
A revenue ruling commits the IRS to a stated position on stated facts, while a publication is explanatory and gives a preparer nothing to rely on if challenged.
Court decisions weighed by forum
The two decisions are ranked by court and by the circuit an appeal would reach, so a trial-level opinion is never presented as settling the law.
Commentary treated as a pointer
The blog post and any tax-service explanation appear only as routes back to primary sources, since neither carries authority on its own terms.
Where marks go in ACC-460 Topic 1
Treating every source in the file as equally weighty is what sinks most versions of this memo. A paper that quotes an IRS publication as though it settled the question has cited a document the IRS itself does not treat as binding. Placing a revenue ruling above the regulation inverts the order the course expects, and explaining why the ruling might still matter on its facts usually separates the stronger papers. Court decisions listed without their forum lose marks, since a Tax Court memorandum decision and a circuit opinion differ in reach. Memos that answer the hobby question instead of ranking the sources have done a later topic's work and skipped this one. Inconsistent citation form also costs credit in many sections, since a table mixing section numbers with page titles cannot be checked quickly.
Get an ACC-460 Topic 1 example written to your instructions
Send the ACC-460 Topic 1 instructions, the rubric from your classroom and the research question or source list your section assigned. We write a custom example to them, with each source placed by issuer and weight and the ordering explained in prose, back in 24 to 48 hours. The first one is free, and it is coursework support rather than tax advice.
ACC-460 Topic 1 questions, answered
Is an IRS publication a source of authority?
Not in the sense a return position needs. Publications explain the IRS's reading of the law in plain language and are useful for orientation, but the IRS does not treat them as binding on itself, and courts have declined to treat them as authority. A memo can mention one as a starting point and then cite the Code section, regulation or ruling that actually supports the treatment.
Why does the forum of a court decision matter?
Because reach differs. A Supreme Court decision binds every court. A circuit court's decision binds the courts within that circuit. The Tax Court hears cases from taxpayers everywhere and follows the precedent of the circuit to which a particular case would be appealed, so the same issue can come out differently for taxpayers in different places. A ranking memo notes the forum of each decision before relying on it.
Should the memo answer the hobby question too?
Usually not at this stage. The point of an opening topic in many sections is to establish which sources may be cited and in what order, so the eventual answer rests on the right foundation. If the assignment does ask for a preliminary view, keep it short, label it tentative and tie it to the section 183 factors rather than to the blog post.