This course empowers the student to synthesize knowledge of professional concepts within a quality caring framework. Content is designed to prepare the student to apply leadership and management principles to achieve positive health outcomes within health care systems.
Introduction to geology and economics of non-energy mineral resources. Emphasis placed on the descriptive geology and origin of economic mineral concentrations within the context of their overall geologic settings. Lab exercises will involve identification and characterization of representative ore suites from important mineral deposits. Students will complete a research project on exploring for or developing a major ore deposit or mineral/rock resource. A fieldtrip is anticipated to examine the geology, exploration methodology, development, and permitting issues related to mineral/rock production. Students will also prepare for and take the National Association of State Boards of Geology, Fundamentals of Geology (FG) professional licensing exam.
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Likewise, taxpayers who rely on other individuals or services to prepare their tax returns are also affected by the IRS simplifications. These taxpayers consult sources such as commercial tax preparation software, tax accountants and tax return preparers, secondary source publications, and the IRS itself. As the following examples illustrate, taxpayers who receive advice from these sources are often indirectly exposed to the simplexity of IRS publications.
Environmental Regulation of Real Property - Law Journal …
Another example of an IRS description that does not fully explain the tax law can be found in the IRS publication regarding early distributions from IRAs. As discussed earlier, if taxpayers under age 59 1/2 withdraw funds from an IRA, such as a § 401(k) plan, they must pay tax on the withdrawn amount plus a 10% early withdrawal tax penalty, unless certain exceptions apply. One such exception is that the taxpayer receives distributions from an IRA in the form of an annuity. Specifically, current law provides that the 10% early withdrawal tax penalty does not apply to “part of a series of substantially equal periodic payments (not less frequently than annually) made for the life (or life expectancy) of the employee or the joint lives (or joint life expectancies) of such employee and his designated beneficiary.” Taxpayers who desire to withdraw funds from an IRA using an annuity arrangement, therefore, must determine whether they will satisfy the distribution requirements for such an annuity.
§ 21.06 Disclosures and Opinion Letters ..
Consider the example of the IRS simplification regarding annuity distributions that avoid the early IRA distribution penalty. As discussed previously, in technical guidance, the IRS has conceded that the three methods of distribution set forth in the IRS publication “do not represent the only distribution methods which will satisfy the requirements of Section 72(t)(2)(A)(iv) of the Code.” Indeed, the IRS has issued private letter rulings allowing particular taxpayers to use distribution methods other than those set forth in the IRS publication. However, this more technical guidance is not equally accessible to all taxpayers. Private letter rulings are expensive and difficult to obtain, and therefore unlikely to be sought by or granted to the average taxpayer. More generally, both private letter rulings and IRS Notices are part of a panoply of technical guidance that the IRS issues, which experienced practitioners routinely access to advise sophisticated clients. In contrast, less sophisticated taxpayers or advisors are unlikely to access (or know about) such guidance. Less sophisticated taxpayers therefore access a much smaller set of choices offered by the simplification in the IRS publication, such as the simplification that taxpayers must use one of the three distribution methods set forth in the IRS publication to avoid a penalty. Sophisticated taxpayers therefore enjoy the best of both worlds: the ability to use taxpayer-favorable IRS simplifications and the ability to reject pro-government IRS simplifications.
§ 22A.02 Asbestos in Schools and ..
Even if it were clear what IRS simplifications are under the APA framework, it is unlikely that the APA framework would actually be applied in practice. Imagine, for instance, that IRS simplifications are clearly mere policy statements. Does this mean that taxpayers will not be compelled to comply with them? As a legal matter, the answer to this question should be yes. However, in order to answer yes to this question from a practical perspective, taxpayers who access IRS publications to complete their tax returns would have to actually know that they are mere policy statements. This is unlikely to be the case for the vast majority of taxpayers, who not only are unlikely to know what IRS simplifications are from an APA perspective, but also that they even diverge from applicable tax law.