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What is the substative regulation pursuant to assessment of…

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What is the substative...

What is the substative regulation pursuant to assessment of income tax, published in the Federal register, according to 26 usc 6323 (1.6323)

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Congress requires .5usc 552 (D) that-"Substantive rules of general applicability adacpted as authorized by law, be published in the Federal Register. Substantive rules affect peoples rights and duties. U.S. Supreme Court- Christler v Brown.

Accountant's Assistant: Is there anything else the Accountant should be aware of?

Yes, the federal apa of 1946,federal registter act of 1935 and 1 CFR PARTS 23.42 ???? NOT CERTAIN ON THIS ONE.

Submitted: 5 months ago.Category: Tax
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Answered in 6 days by:
11/22/2017
Tax Professional: Carter McBride, Certified Public Accountant (CPA) replied 5 months ago
Carter McBride
Carter McBride, Certified Public Accountant (CPA)
Category: Tax
Satisfied Customers: 1,038
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Hey, I'm Nick. I'd love to help you out with this question. Substantive law is shows how people are supposed to act. Under 6323, we are looking at how courts are supposed to enforce a lien if more than one creditor has been attached to the lien. The original substantive law on this then is IRC 6323 as that sets the lien priority. However, if you want to point to case law, then you'd look to ***** v. City of New Britain, 347 U.S. 81 (1954) which established the first in time first to right doctrine which says the first person to file the lien is the first person to get the priority claim.

The IRS provides a good Chief Counsel Advice (CCA) on this available here: https://www.irs.gov/pub/irs-wd/0922049.pdf.

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Tax Professional: Carter McBride, Certified Public Accountant (CPA) replied 4 months ago

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