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of local collectors, comprising several thousand persons. Divisions and sections are the subsidiary units into which the Bureau is divided, each headed by a "chief." A Deputy Commissioner is directly in charge of the Income Tax Unit. A brief summary of certain divisions of the Unit will be of interest:

1. Consolidated Returns Audit division: five sections for commercial organizations and one for railroads.

2. Corporation Audit division: further subdivided into separate sections for manufacturing, trading, public utilities and personal service, finance, and so forth.

3. Engineering division: consists of oil and gas, timber, mining, and appraisal sections, each concerned with problems of valuation as at March 1, 1913, of amortization, and so forth.

4. Personal Audit division: six sections for the examination of personal and partnership returns.

5. Field divisions: each headed by an "internal revenue agent in charge." There are 36 field divisions at present, located at the offices of local collectors at strategical points throughout the country. These divisions have been given. authority to deal directly with taxpayers concerning disputed matters of fact upon the completion of field audits.

The Committee on Appeals and Review was, prior to the passage of the 1924 act, an important unit of the Bureau of Internal Revenue and was in existence nearly five years. To this Committee the taxpayer could take his case if he found he could not agree with the decision of the Income Tax Unit. Although the Committee operated independently, its membership was chosen mostly from the Income Tax Unit. Decisions of the Committee were accepted by the Income Tax Unit, being subject to review only by the Commissioner and the courts. Nevertheless, it was felt by Congress that its functions were primarily judicial and that it, or a body similar to it, should be separated from the De

partment, which otherwise would be prosecutor, judge, and jury.

Decentralization of the Bureau's activities has been urged from most quarters. The inconvenience and expense to which a taxpayer is put where he believes it necessary to present his case orally are, it is true, somewhat lessened through the present limited authority of the field divisions. But the field divisions have thus far been permitted to deal only with cases under audit and their decisions are subject to review after transmittal to Washington.

BOARD OF TAX APPEALS

The Board of Tax Appeals, created by Congress in the Revenue Act of 1924, is an independent body with judicial powers, whose members are appointed by the President with the consent of the Senate. Both the Treasury Department and the taxpayer may appeal to the courts from its decisions. The act of 1926 increased the powers of the Board.

At present the Board has 16 members. Divisions of the Board occasionally hold hearings outside Washington.

RULINGS ISSUED BY THE DEPARTMENT

As soon as possible after the passage of an income tax act, the Treasury Department has issued a "regulation" embodying its interpretations of the law and its rules, which Congress has always permitted it to lay down, detailing the computation of taxable income, filing of returns, and so forth. Since 1909 the regulations' have been issued under revenue acts as indicated at the top of the opposite page.

Many of the old rulings have been set aside so that any of the above regulations cannot be considered without a

1 Regulations 69 may be obtained without cost from local collectors and deputy collectors, or at 40 cents per copy from the Government Printing Office. Few collectors' offices will have on hand copies of the other regulations referred to.

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review of all the changes that have taken place since the date of original issue. Before 1919 none of these changes were available to taxpayers; in that year the "Bulletin" service was inaugurated whereby for a nominal sum a taxpayer may receive each week a copy of the most recent rulings of the Department. The weekly bulletins also contain the full text of all relevant court decisions.

The general arrangement of Regulations 45, 62, 65, and 69 is as follows:

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(Other sections of the law have referred to excise taxes, the capital stock tax, estate tax, and so forth.)

Only Treasury decisions can modify the various regulations which have been issued. Modifications of rules are not retroactive in effect, unless so designated by the Commissioner (Sec. 1108 1).

The Internal Revenue Bulletin Service, consisting of weekly bulletins of income tax rulings, quarterly digests of rulings, and semi-annual cumulative bulletins with the full rulings of the previous six months' weekly bulletins, is in ad

1 "Sec. 1108" means section 1108 of the Revenue Act of 1926 and may be read in full on page 272 of Regulations 69 or on page 554 hereinafter.

SOURCES AND ABBREVIATIONS OF INCOME TAX DECISIONS
AND OPINIONS

Source

Federal Court Decisions....

Abbreviation

.Ct. D.

Opinions of the Attorney General...Op. A. G.

Decisions of the United States

Board of Tax Appeals..... .. B. T. A. Treasury Decisions (sometimes including Supreme, and other Fed

eral Court decisions)...... .T. D.

Memoranda of the General Counsel

(Internal Revenue).

Opinions, Memoranda, and Recom

..G. C. M.

mendations of the Solicitor of In- O. or L. O., S. or S. M., Sol. ternal Revenue

Mimeographed Information for

Collectors

Recommendations and Memoranda
of the Advisory Tax Board
(1919 only) ..

Recommendations and Memoranda
of the Committee on Appeals and
Review

Office Decisions

Op., and S. R.

.Mim.

.T. B. R. and T. B. M.

.A. R. R. and A. R. M.
..O. D. and I. T.

dition to, and modifies, Regulations 69 and other previous rulings and opinions. The decisions and opinions listed above, and indexed on page v, are contained in this weekly service.

The "Bulletin" service, as listed on the opposite page, may be purchased from the Superintendent of Documents, Government Printing Office, Washington, D. C. The total cost will be $6.95.

Rulings of the Board of Tax Appeals may be obtained from the same source at a price of $1.50 per volume. Volumes I and II (to November 11, 1925) are now available.

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Under an act passed by Congress in 1884 the Secretary of the Treasury has the right to admit or disbar agents and attorneys to practice before the various bureaus of his department. Regulations governing this admission to practice include the following (abstracted from Department Circular Number 230, dated August 15, 1923):

(a) Applications must be made on Form 231 for both members of the bar (designated in the regulations as attorneys) and accountants and others (designated as agents). Attorneys and agents may represent claimants in the name of a partnership (professional partnership) but not in the name of a corporation.

(b) Disbarment may be warranted by (1) violation of the ethical rules of the American Bar Association, (2) misleading statements made to a taxpayer or to the Department, (3) statements, except in formal announcements, indicating previous connections with the Department or acquaintance with officials thereof, (4) use of such titles as "Federal tax expert," and (5) assistance rendered to or by a disbarred attorney or agent.

1 Included in Department Circular 230.

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