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Federal Tax Research, Tenth Edition © 2015, 2012 Cengage Learning
Roby B. Sawyers, William A. Raabe, WCN: 02-200-203
Gerald E. Whittenburg, Steven L. Gill
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Dedications
This book is dedicated to our academic mentors.

Roby B. Sawyers
David E. Hoffman
Charles W. Christian
J. Hal Reneau
Philip M. J. Reckers
Joseph J. Schultz, Jr.
William A. Raabe
Norton M. Bedford
Gerald D. Brighton
Christine M. Purdie
Joseph J. Schultz, Jr.
Eugene Willis
Gerald E. Whittenburg
William H. Hoffman
James W. Pratt
John J. Willingham
Allan R. Bailey
Steven L. Gill
Susan Porter
Lynne Krapf
Gene Whittenburg

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Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
Copyright 2015 Cengage Learning. All Rights Reserved. May not be copied, scanned, or duplicated, in whole or in part. Due to electronic rights, some third party content may be suppressed from the eBook and/or eChapter(s).
Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
About the Authors

Roby B. Sawyers, Ph.D., CPA, CMA, is a professor in the Poole College of Management at
Photo Courtesy of Roby B. Sawyers

North Carolina State University. He earned his undergraduate accounting degree from the
University of North Carolina at Chapel Hill, his master’s degree from the University of
South Florida, and his Ph.D. from Arizona State University. He has taught a variety of
undergraduate and graduate tax courses at NC State and has been a visiting professor in
the International Management Program at the Catholic University in Lille, France, and the
Vienna School of Economics and Business (Wirtschaftsuniversitat Wien). He has also
developed and taught continuing education courses for the AICPA, NCACPA, BDO
Seidman, McGladrey, Dixon Hughes Goodman, and PricewaterhouseCoopers.
In addition to being on the author team of Federal Tax Research, Dr. Sawyers is an author
of Managerial Accounting: A Focus on Ethical Decision Making (Fifth Edition) and Managerial
ACCT and writes frequently for leading academic, policy, and professional tax journals.
Dr. Sawyers has been an active member of the AICPA’s Tax Division, currently
serving as chair of the Tax Legislation and Policy Committee. He has also served on the
Tax Executive Committee, as chair of the Trust, Estate and Gift Tax Technical Resource
Panel, and chair of the AICPA’s task force on estate tax reform.

William A. Raabe, Ph.D., CPA, is the Distinguished Professor of Accounting in the College
Photo Courtesy of William A. Raabe

of Business and Economics of the University of Wisconsin–Whitewater. A graduate of


Carroll University (Wisconsin) and the University of Illinois, Dr. Raabe’s teaching and
research interests include international and multistate taxation, technology in tax educa-
tion, and personal financial planning. Professor Raabe also writes and edits the Southwest-
ern Federal Taxation series and the PricewaterhouseCoopers Tax Case Studies. Dr. Raabe
has been a visiting tax faculty member for a number of public accounting firms, bar asso-
ciations, and CPA societies. He has received numerous teaching awards, including the
Accounting Educator of the Year award from the Wisconsin Institute of CPAs. He has
been the faculty adviser for student teams in the Deloitte Tax Case Competition (national
finalists at three different schools) and the PricewaterhouseCoopers Tax policy competition
(national finalist). For more information about Dr. Raabe, visit BillRaabeTax.com and
BillRaabeTax on YouTube and Twitter.
Photo Courtesy of Gerald E. Whittenburg

Gerald E. Whittenburg, Ph.D., CPA, EA, is a professor in the Charles W. Lamden School
of Accountancy at San Diego State University. A graduate of the University of Houston,
Dr. Whittenburg is interested in individual and corporate taxation, tax pedagogy, and tax
research methodology.
Dr. Whittenburg is also an author of the textbook Income Tax Fundamentals (which
is in its 33rd edition). In addition, he has published more than 90 articles in journals such
as Accounting Education: An International Journal, Accounting Review, Advances in Taxa-
tion, Practical Tax Strategies, Taxes— The Tax Magazine, Group Decision and Negotiation,
Journal of Business and Accounting, Journal of Legal Tax Research, Journal of Taxation of
Investments, Journal of Taxation of Employee Benefits, Journal of Taxation of Financial
Institutions, Valuation Strategies, Journal of Small Business Strategy, The Tax Adviser, and
Journal of Accounting Education. He has received numerous awards for teaching, including
the Trustee’s Outstanding Faculty Award for the entire California State University System.
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vii
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Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
viii About the Authors

Dr. Whittenburg was awarded a Fulbright Fellowship (2003) to the Ukraine. In addition,
he has been a visiting scholar at the University of Adelaide (1999 and 2005) and the
University of South Australia (2009 and 2010).
In August 2013, Dr. Whittenburg stepped down as director of the Charles W. Lamden
School of Accountancy and returned to the teaching faculty. This was his fourth time
serving as director of the School of Accountancy in his 38 years on the faculty.

Steven L. Gill, Ph.D. is an Associate Professor in the Charles W. Lamden School of


Accountancy at San Diego State University. He received a BS in Accounting from the
Photo Courtesy of Steven L. Gill

University of Florida, an M.S. in Taxation from Northeastern University (Boston) and a


Ph.D. in accounting from the University of Massachusetts. Before entering academia,
Professor Gill worked for 12 years in the field of accounting, including roles in public
accounting, internal audit, and corporate accounting and, ultimately, as a vice president of
finance.
Professor Gill’s research interests include a concentration in taxation including mutual
funds and college savings (“529”) plans and wider interests in corporate internal control
structure and weaknesses, management overconfidence, and earnings quality. Professor
Gill has taught at both the undergraduate and graduate levels, and his teaching interests
include taxation and financial accounting. In addition to being on the author team of
Federal Tax Research, Dr. Gill is an author of Income Tax Fundamentals.

Copyright 2015 Cengage Learning. All Rights Reserved. May not be copied, scanned, or duplicated, in whole or in part. Due to electronic rights, some third party content may be suppressed from the eBook and/or eChapter(s).
Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
Brief Contents

PART I THE TAX RESEARCH ENVIRONMENT 1

CHAPTER 1 Introduction to Tax Practice and Ethics 3


CHAPTER 2 Tax Research Methodology 51

PART II PRIMARY SOURCES OF FEDERAL TAX LAW 81


CHAPTER 3 Constitutional and Legislative Sources 83
CHAPTER 4 Administrative Regulations and Rulings 117
CHAPTER 5 Judicial Interpretations 149

PART III RESEARCH TOOLS 189


CHAPTER 6 Thomson Reuters Checkpoint 191
CHAPTER 7 CCH IntelliConnect 239
CHAPTER 8 Other Tax Services and Tax Periodicals 279
CHAPTER 9 Multijurisdictional Taxes 323
CHAPTER 10 Financial Accounting Research 385

PART IV IMPLEMENTING THE RESEARCH TOOLS 407


CHAPTER 11 Communicating Research Results 409
CHAPTER 12 Tax Planning 433
CHAPTER 13 Working with the IRS 457
CHAPTER 14 Tax Practice and Administration 489

Glossary 531
Index 543

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ix
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Copyright 2015 Cengage Learning. All Rights Reserved. May not be copied, scanned, or duplicated, in whole or in part. Due to electronic rights, some third party content may be suppressed from the eBook and/or eChapter(s).
Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
Contents

Preface xvii Step 1: State the Issue as a Question 65


Step 2: Identify the Keywords 66
PART I Step 3: Construct a Research Query 66
Step 4: Select a Database and Execute the
The Tax Research Environment 1
Search 67
Step 5: Interpret and Refine the Search 67
Chapter 1
Research on irs.gov 67
Introduction to Tax Practice and Ethics 3
Tax Research Practical Considerations 68
Elements of Tax Practice 5 Research on the CPA Exam 70
Tax Compliance 5 Summary 71
Tax Planning 6
Quiz Yourself 71
Tax Litigation 6
Key Words 72
Tax Research 7
Discussion Questions 72
Rules and Ethics in Tax Practice 7
Exercises 75
Circular 230 7
Research Cases 77
Proposed Changes to Circular 230 15
AICPA Code of Professional Conduct 17
Statements on Standards for Tax Services 22 PART II
Sarbanes-Oxley and Taxation 28 Primary Sources of Federal Tax Law 81
ABA Model Rules of Professional Conduct 29
Nonregulatory Ethical Behavior Models 29 Chapter 3
Ethical Dilemmas 29 Constitutional and Legislative Sources 83
Ethical Professional Behavior 31 Sources of Federal Tax Law 84
Ethics Training and Education 35 History of U.S. Taxation 84
Legal Research by Certified Public Accountants 36 Who Pays the Income Tax? 86
Summary 38 Tax Protesters 87
Quiz Yourself 38 U.S. Constitution 88
Key Words 38 Tax Treaties 89
Discussion Questions 39 The Legislative Process 91
Exercises 42 Where to Find Committee Reports 94
Research Cases 46 Internal Revenue Code 95
Organization of the Internal Revenue Code 96
Chapter 2
Where to Find the Internal Revenue Code 99
Tax Research Methodology 51
Interpreting the Internal Revenue Code 102
The Tax Research Process 53 Summary 104
Step 1: Establish the Facts 53 Quiz Yourself 104
Step 2: Identify the Issues 54 Key Words 104
Step 3: Locate Authority 57 Discussion Questions 105
Step 4: Evaluate Authority 59 Exercises 106
Step 5: Develop Conclusions and
Research Cases 112
Recommendations 60
Step 6: Communicate the Recommendations 60
Overview of Online Tax Research 62 Chapter 4
Benefits of Using Online Tax Services 62 Administrative Regulations and Rulings 117
Using an Online Tax Service to Conduct Tax Regulations 118
Research 65 Temporary Regulations 119
xi
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Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
xii Contents

Effective Date of Regulations 120 PART III


Citing a Regulation 120 Research Tools 189
Assessing Regulations 122
Locating Regulations 123 Chapter 6
Revenue Rulings 123 Thomson Reuters Checkpoint 191
Revenue Ruling Citations 125 Using Tax Services for Research 192
Locating Revenue Rulings 125 Thomson Reuters Checkpoint 193
Revenue Procedures 125 Illustrative Research Example 193
Letter Rulings 127 Approaching the Research Problem 194
Private Letter Rulings 127 Accessing Tax Information 194
Technical Advice Memoranda 128 Databases 195
Determination Letters 129 Finding Relevant Tax Information 202
Precedential Value of PLRs, TAMs, Keyword Search 202
and Determination Letters 129 Index Search 210
Written Determination Numbering System 130 Contents Search 213
Locating Written Determinations 130 Citation Search 215
Other IRS Pronouncements 130 Citators 218
Acquiescences and Nonacquiescences 130 Other Tax Law Sources 222
Internal Revenue Bulletin 132 Tax Treatises 222
Chief Counsel Memoranda 134 Tax Periodicals 225
Announcements and Notices 134 Utilizing Treatises and Periodicals in Tax
Miscellaneous Publications 134 Research 225
Summary 137 Other Research Tools 225
Quiz Yourself 137 Summary 227
Key Words 138 Quiz yourself 227
Discussion Questions 138 Key Words 227
Exercises 141 Discussion questions 227
Research Cases 144 Exercises 229
Research Cases 232
Chapter 5 Advanced Cases 236
Judicial Interpretations 149 Cumulative Case 237
Federal Court System 150
Legal Concepts and Terminology 152 Chapter 7
U.S. Tax Court 155 CCH IntelliConnect 239
District Courts 161 Using Tax Services for Research 240
Court Reporters 163 CCH IntelliConnect 241
Court of Federal Claims 163 Illustrative Research Example 241
Court Reporters 164 Approaching the Research Problem 242
Courts of Appeals 164 Accessing Tax Information 242
Court Reporters 167 Databases 243
Supreme Court 167 Finding Relevant Tax Information 248
Court Reporters 171 Keyword Search 249
Case Briefs and Headnotes 171 Index Search 253
Summary 172 Contents Search 257
Quiz Yourself 174 Citation Search 258
Key Words 174 Citators 260
Discussion Questions 174 Other Tax Law Sources 263
Exercises 177 Tax Treatises 264
Research Cases 180 Tax Periodicals 265

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Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
Contents xiii

Utilizing Tax Treatises and Periodicals in Tax Public Law 86-272 329
Research 265 State Tax Structure 330
Other Research Tools 266 Constitution 330
Summary 267 Legislative 331
Quiz Yourself 268 Administrative 331
Key Words 268 Judicial 332
Discussion Questions 268 Multistate Taxation 333
Exercises 269 Illustrative Research Example 334
Research Cases 273 Checkpoint State and Local Tax (SALT)
Advanced Cases 276 Service 335
Cumulative Case 278 CCH IntelliConnect State 340
Bloomberg BNA 342
Chapter 8 Lexis Tax Center 345
Other Tax Services and Tax Periodicals 279 LexisNexis Academic 345
BNA Bloomberg 280 WestlawNext State Services 350
BNA Portfolios 281 Other Resources 351
Searching the BNA Collections 281 Periodicals and Internet Sites 351
Browsing the BNA Collections 284 International Taxation 352
Westlaw 289 International Tax Models 353
Searching WestlawNext 290 Transfer Pricing 354
KeySearch and KeyCite 293 Sourcing of Income and Deductions 356
LexisNexis 294 Tax Treaties 357
Tax Center 295 Researching International Tax 358
LexisNexis Academic 300 Checkpoint 358
LexisNexis & Shepard’s Citators 303 CCH IntelliConnect 360
Tax Periodicals 306 Bloomberg BNA 362
Annual Proceedings 307 Tax Treaties 364
Scholarly Reviews 308 Westlaw 365
Professional Journals 308 LexisNexis 366
Newsletters 309 Internet Sites 370
Tax Analysts 309 Summary 370
BNA Publications 311 Quiz Yourself 370
Locating Relevant Tax Articles 311 Key Words 370
Citing Articles in Tax Periodicals 312 Discussion Questions 371
Summary 313 Exercises 372
Quiz Yourself 313 Research Cases 377
Key Words 313 Cumulative Case-State 382
Discussion Questions 313 Cumulative Case – International 383
Exercises 314
Research Cases 318 Chapter 10
Financial Accounting Research 385
Chapter 9 Accounting for Income Taxes 386
Multijurisdictional Taxes 323 GAAP and the Financial Accounting Standards
State and Local Tax 324 Board (FASB) 387
Importance of State and Local Taxes 325 International Standards 388
Legal Perspective 326 The FASB Codification 388
Taxing Out-of-State Taxpayers 328 FASB Accounting Standards Codification Research
Due Process Clause 328 System (CRS) 389
Commerce Clause 328 Structure 390

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xiv Contents

Browsing 393 Summary 452


Search 397 Quiz Yourself 453
Go To 397 Key Words 453
Join Sections 399 Discussion Questions 453
Cross Reference 399 Exercises 454
Other Sources and Services 401 Problems 454
Summary 403
Quiz Yourself 403 Chapter 13
Key Words 403 Working with the IRS 457
Discussion Questions 403
The Internal Revenue Service 458
Exercises 404
Organization of the IRS 458
Research Cases 404
Taxpayer Rights 466
The Audit Process 466
Preliminary Review of Returns 467
PART IV
Selection of Returns for Examination 468
Implementing the Research Tools 407
Examinations 471
Correspondence Examinations 471
Chapter 11
Office Examinations 472
Communicating Research Results 409
Field Examinations 472
Communications and the Tax Professional 410 Dealing with an Auditor 473
The Heart of Tax Research Communication: Conclusion of Examination 474
The File Memo 412 30-Day Letter 474
Evaluating the Sources of Law 415 File a Protest or Go Straight to Court? 474
Client Letters 416 The Appeals Process 475
Comprehensive Illustration of Client File 420 Registered Tax Return Preparers and Unenrolled
Oral Presentations of Research Results 422 Return Preparers 475
Summary 426 Appeals Conference 476
Quiz Yourself 426 90-Day Letter 476
Key Words 426 Entering the Judicial System 477
Tax Research Assignments 426 Statutory Agreements 481
Research Cases 427 Closing Agreements 481
Offers in Compromise 482
Summary 484
Chapter 12
Quiz Yourself 484
Tax Planning 433
Key Words 484
The Economics of Tax Planning 434 Discussion Questions 484
Tax Rate Terminology 436 Exercises 485
Tax Base 436 Problems 487
Tax Rates 437
Research Cases 487
Tax Planning in Perspective 440
Fundamentals of Tax Planning 441
Avoiding Recognition of Taxable Income 443 Chapter 14
Changing the Timing of Recognition of Income, Tax Practice and Administration 489
Gains, Deductions, Losses, and Credits 444 Taxpayer Penalties 490
Changing Tax Jurisdictions 446 Civil Penalties 491
Changing the Character of Income 447 Criminal Penalties 502
Tax Planning among Related Taxpayers 448 Penalties on Return Preparers 505
Avoiding Tax Traps 450 Definition of Return Preparer 505
Statutory Tax Traps 450 Preparer Disclosure Penalties 507
Judicial Tax Traps 451 Preparer Conduct Penalties 507

Copyright 2015 Cengage Learning. All Rights Reserved. May not be copied, scanned, or duplicated, in whole or in part. Due to electronic rights, some third party content may be suppressed from the eBook and/or eChapter(s).
Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
Contents xv

Injunctions 512 Mitigation of Statute of Limitations 521


Action to Enjoin TRPs 512 Summary 521
Action to Enjoin Promoters of Abusive Tax Quiz Yourself 521
Shelters 513 Key Words 521
Interest 513 Discussion Questions 522
Interest-Computation Conventions 513 Exercises 523
Statutes of Limitations 516 Research Cases 526
Assessment 516
Collection 518
Claim for Refund or Credit 518 GLOSSARY 531
Suspension of Period of Assessment and
Collection 520 INDEX 543

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Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
Copyright 2015 Cengage Learning. All Rights Reserved. May not be copied, scanned, or duplicated, in whole or in part. Due to electronic rights, some third party content may be suppressed from the eBook and/or eChapter(s).
Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
Preface

The Tenth Edition of Federal Tax Research includes the deepest analysis of the online
research tools available to assist with tax and accounting research. As a result, we believe
that the Tenth Edition is indispensable to learning and performing real-world research.
New features in the Tenth Edition include:
• A research-case-classification matrix for all chapters with research cases. The new
matrix classifies all research cases in the book by primary tax law source (legislative,
administrative, judicial), jurisdiction (federal, state, international), entity type or
issue, tax type, the similarity of the research case to the facts in the primary sources,
the types of research sources needed to answer the case questions, and the expected
student response (short paragraph, research memo, etc.).
• Cumulative research problems that continue from chapter to chapter.
• A complete reorganization of the Research Tools section of the book with separate
chapters for Thomson Reuters Checkpoint and CCH IntelliConnect. Coverage and
illustrations of research using BNA Bloomberg, Westlaw, and LexisNexis have been
combined into a third chapter, with state and international tax services combined
into a fourth chapter on multijurisdictional tax issues.
• Additional updated examples of tax research memos and client letters.
• Updates of rules affecting tax practice, including Circular 230 revisions and regula-
tions, the AICPA Statements on Standards for Tax Services (SSTS), CPA mobility
across states, and recent IRS litigation concerning registered tax-return preparers.
• Updated information on tax and research on the CPA exam as well as on conduct-
ing searches at irs.gov.
• Increased focus on tax planning, including the importance of considering both par-
ties in a transaction and examples of calculating marginal tax rates in the presence
of net operating losses.
The book has been prepared as a comprehensive, stand-alone reference tool for the
user who wishes to become proficient in federal, multistate, and international
tax research as well as financial accounting research. It is written for readers who are
familiar with the fundamentals of the tax law, at a level that typically is achieved on the
completion of two comprehensive introductory courses in taxation in either the account-
ing program in a business school or second- or third-year courses in a law school. Nearly
every accounting, tax, and tax law student can benefit from the tools and strategies found
in this book. The text is most appropriate for:
• Upper-level accounting students in a business school (i.e., seniors in a four-year
program or those in the fifth year of a 150-hour program) who desire additional
information concerning the practice of taxation.
• Students enrolled in a non-tax graduate program in business administration (e.g., an
MBA or MS–management program) and would like further practical training in the
functions of taxation in today’s business environment.

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xvii
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Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
xviii Preface

• Second- or third-year law school students, especially those who desire a more
detailed and pragmatic introduction to a specialized tax practice.
• Students commencing a graduate degree program in taxation, in either a business
school or a law school, and require a varied and sophisticated introduction to the pro-
cedures of tax research and to the routine functions and implications of a tax practice.
• Practicing accountants and attorneys who need an introduction, an update, or a
refresher concerning tax practice and research as an element of their career paths.

Structure and Pedagogy


Too often, existing textbooks ignore the detailed, pragmatic approach that students
require in developing effective and efficient tax research skills. That is why we have
included an unprecedented degree of hands-on tax research analysis throughout the
text. This book does not simply discuss tax research procedures or the sources of the
tax law nor does it provide a mere sample of the pertinent tax reference material. Rather,
the book reflects our conviction that students learn best by active learning and real-world
experience using the most comprehensive and important sources of tax law. We have
applied this conviction to the many important features of the Tenth Edition, including:
• Dozens of exercises, problems, and research cases in each chapter.
• “Spotlight on Taxation” boxes in every chapter to provide additional research tips,
news, and background information to students.
• Chapters on working with the IRS and on tax practice and administration that pro-
vide details on important topics such as preparer penalties, statutes of limitations,
and the IRS audit and appeals process.
• Assignments requiring students to construct case briefs, file memos, client letters,
and other elements of a comprehensive client file—vital communication skills they
will need in practice.
• Hundreds of reproductions, illustrations, and screen captures from the most impor-
tant tax reference materials to expose students to the real world of tax research.
• Summary charts, diagrams, and other study aids integrated throughout the text.
Other important features for students and instructors include the following:
• The “Quiz Yourself” feature at the end of each chapter directs students to the online
quizzes located on the book’s Web site through www.cengagebrain.com. Here,
students will have access to online quizzes, complete with immediate answers and
feedback for questions answered incorrectly. The feedback will direct students to
the section of the chapter that contains the correct answer.
Students can also access chapter-by-chapter study content at the CengageBrain.com
home page and can search by author name, title (Federal Tax Research), or ISBN
(1285439392) using the search box at the top of the page. This will bring readers to a
link for the tenth edition of Federal Tax Research.
The instructor’s portion of the Web site for the text, located at www.cengagebrain.com,
includes the solutions for the end-of-chapter material, a test bank, instructor PowerPoint
slides, lecture notes, and the new research case classification matrix to help guide instructors
through the course.

Copyright 2015 Cengage Learning. All Rights Reserved. May not be copied, scanned, or duplicated, in whole or in part. Due to electronic rights, some third party content may be suppressed from the eBook and/or eChapter(s).
Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it.
Preface xix

Using the Text


The main tax services are reviewed in a hands-on manner. Learning how to use the
services is explained through example projects that guide the reader with step-by-step
explanations and screen shots to illustrate what is actually seen on the screen. The
text’s exercises, cases, and advanced cases offer enough variety in both difficulty and
subject matter that they may be assigned to individual readers, or to student groups
of two or three, for their optimal use. The instructor also should consider giving each
student in the course a different research case to complete, thereby discouraging joint
work.
Given both the nature of the tax research process and the limited tax research
databases available to most firms and universities, the instructor must take care to
assign discussion materials for which the necessary resources are available and also
to work through the assignment himself or herself, to ascertain that one’s target
solution to the assignment reflects the very latest in the development of the federal
tax law.
The instructor may want to defer the assigning of certain research cases until a
specific research service is discussed, which will provide additional illustrations. Alterna-
tively, the reader could be encouraged to rework a previous assignment as specific
research services are introduced.

Acknowledgments
We are grateful to our supplement authors and reviewers who provided valuable
comments and insights, which guided us in the development of the Tenth Edition.
Beth Howard, Tennessee Technological University
Chuck Pier, Angelo State University
Courtney H. Edwards, University of North Carolina at Chapel Hill
Fernando Rodriguez
George Starbuck, McMurry University
J. David Golub, Northeastern University
James P. Trebby, Marquette University
Jeff Varblow, The College of Lake County
Lucia Smeal, Georgia State University
Paul A. Shoemaker, University of Nebraska–Lincoln
Rose L. Bailey, East Carolina University
Sally Cook, Texas Lutheran University
Sandra Owen, Indiana University–Bloomington
Susan E. Anderson, Appalachian State University
Tori Fischer Golden Gate University
Wilson Seda, Lehman College, CUNY
We wish to thank all of the book’s student and faculty readers who have provided
their detailed feedback and suggestions. Without their responses, our efforts would
have been greatly diminished in scope. Any errors, of course, are the sole responsibility
of the authors.

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xx Preface

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Please feel free to use the following addresses to convey these remarks:
Roby B. Sawyers
Department of Accounting, Poole College of Management
NC State University
Raleigh, NC 27695-8113
roby_sawyers@ncsu.edu
William A. Raabe
College of Business and Economics
University of Wisconsin-Whitewater
Whitewater, WI 53190
raabew@uww.edu
Gerald E. Whittenburg
Charles W. Lamden School of Accountancy
San Diego State University
San Diego, CA 92182-8221
gwhitten@mail.sdsu.edu
Steven L. Gill
Charles W. Lamden School of Accountancy
San Diego State University
San Diego, CA 92182-8221
sgill@mail.sdsu.edu
Roby B. Sawyers
William A. Raabe
Gerald E. Whittenburg
Steven L. Gill
January 2014

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PART I

The Tax Research Environment

CHAPTER 1 Introduction to Tax Practice and Ethics 3

CHAPTER 2 Tax Research Methodology 51

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a. The ingestion of bile into the stomach and abdomen. This being
absorbed and carried to the liver greatly increases the biliary
secretion. It is not necessary that the bile shall be a product of the
same genus of animal, the bile of the ox is an active stimulant of the
liver of the dog.
b. Of medicinal agents the following increase and liquefy the bile:
olive oil in large doses, phosphate of soda, salol, and salicylate of
soda.
c. The following not only increase the bile, but through their
purgative operation, expel it from the bowels: calomel, mercuric
chloride, colocynth, aloes, jalap, rhubarb, podophyllin, and cold
rectal injections. These accordingly lessen the secretion later, by
removing the stimulus of the absorbed bile.
d. The following are comparatively mild biliary stimulants: benzoic
acid, benzoate of soda, oil of turpentine, terpene, terpinol, and
euonymus, and still less active are alkaline bicarbonates, bromides,
sulphates and chlorides, arsenic and ether.
Secretion of bile is lessened by: starvation, a too fatty dietary,
alkaline iodides, atropia, strychina, hepatic degenerations, (fatty,
cirrhosis), catarrh of the bile ducts, diseases of the liver, gall duct, or
duodenum which interfere with the discharge of bile, the antisepsis
of the bowels, or the reabsorption of bile. This work virtually moves
in a vicious circle, as the action of septic ferments in the duodenum
hinders the reabsorption of bile and of the food products which go to
the production of bile, and in its turn the withholding of bile from the
intestine removes the normal antiseptic (the bile acids) and favors
septic fermentation and the inhibition of duodenal digestion and
absorption. Another factor is found in the ptomaines and toxins
absorbed from the alimentary canal and arrested in the liver. These
debilitate the liver cells, impair the liver functions and lay the gland
open to bacteridian infection. The bile in such a case is transformed
into a pale or yellow, viscid liquid, with more or less dark colored
granular debris, and this proves a favorable culture ground for
bacteria especially the golden staphylococcus and the bacterium coli
commune. With septic condition of the liver the usual result of
ligature of the bile duct is a peri- and intralobular sclerosis and the
formation of minute biliary abscesses. In the absence of sepsis,
ligature of the biliary duct, produces—not abscess but—necrobiosis,
preceded by interlobular connective tissue hyperplasia, and granular
or fatty degeneration of the hepatic cells. (Charcot, Legg, Lahousse,
Dupre).
THE LIVER AS A DESTINATION AND
DESTROYER OF POISONS.
The liver in the mature animal, being the one destination of the
blood carried in the portal vein, necessarily becomes the recipient of
all medicinal and poisonous agents absorbed by the capillaries and
venous radicals of the stomach and intestines. This organ retains and
lays up for a time the heavier metals, such as the salts of copper and
iron, the iodides and bromides, the vegetable alkaloids such as
nicotine, quinine, morphia, and curare, the toxic elements of the bile,
the ptomaines and toxins produced by gastric and intestinal
fermentations, indol, phenol, etc. Some agents it transforms, as
peptones (which it renders non-poisonous), casein, the carbonate of
ammonia and its salts with vegetable acids, also indol and phenol,
which it combines with sulphuric acid as indyxol and phenyl
sulphate, thus rendering them much less toxic. The destructions or
new combinations established in the cases of the ptomaines and
toxins may explain why such agents are usually much less poisonous
when taken by the stomach than when generated in tissues or blood,
or when injected hypodermically. Another interesting fact in
connection with the ingestion of these bacteridian products
(ptomaines and albumoses) is that, when the liver functions are
normal as evidenced by the production of glycogen, the toxins are
largely destroyed, and they fail to produce poisoning, whereas with a
functionally deranged liver and no production of glycogen, they
retain their potency, almost as if injected subcutem.
FUNCTIONAL DISORDERS OF THE LIVER.
MELLITURIA, GLYCOSURIA, DIABETES MELLITUS,
SACCHARINE URINE.
Source of glucose in food. Glycogen: Its use: Enlarged liver means more
glycogen. Glycosuric centre in medulla. Other glycosuric nerve centres. Reflex
action, action of drugs and poisons, phlorizin. Disease of lungs or pancreas.
Removal of pancreas in dogs. Removal of thyroid. Diseased, liver, fatty, fibroid,
hypertrophy, congestion. Extreme fatty change arrests glycogenesis. In solipeds: 3
cases with liver hypertrophy; 1 case with adenitis; 6 cases with emaciation; 2 cases
with hæmoglobinuria. Symptoms: Emaciation, debility, langor, fatigue,
breathlessness, hollow flanks, unthrifty skin, ardent thirst, polyuria, urine
saccharine, of high density. Diagnosis by analysis of urine, sweet taste, Fehling’s
test, Trommer’s test, fermentation test. Prognosis: Grave, diet being carbonaceous,
when functional resulting from curable disease is hopeful. Treatment: In poisoning
cases, antidotes and eliminants, in curable disorders treat these, in more inveterate
cholagogues, antiseptics, codeine, opium, croton chloral, strychnia, phosphoric
acid, iodoform, ergot, skim milk or buttermilk, good hygiene, open air, shelter,
carminatives, bitters, mineral acids, treat complications.
Grape sugar (glucose, C6H12O6) is undoubtedly formed in the
stomach and intestines by the action of saliva and pancreatic juice on
starch (C6H10O5), and glucose and laevulose (C6H12O6) are also
derived from the transformation of cane sugar (C12H12O11). These
sugars are absorbed, transformed into glycogen in the liver and
passed into the circulation, where they serve to maintain animal heat
through their decomposition into carbonic acid and water. They
further assist in nutrition and growth, and if their metamorphosis is
imperfect they pass out of the system in the urine, producing a
temporary glycosuria. As shown above glycogen is produced in the
liver cells, and stored up there, in greatest abundance during
digestion of starchy and saccharine food, but it is also formed in
animals kept on a purely albuminous diet, (flesh), and in the fœtal
calf and unhatched chick to which neither starch nor sugar has been
furnished as food. It is produced during the decomposition of
albuminoids, along with the other end products, leucin, tyrosin and
urea. None of these last three is found in the portal vein nor bile
ducts, but all four are found in the liver cells, and in the hepatic
veins.
In health a physiological balance is maintained by the oxidation of
the glucose, mainly in the lungs, so that in the blood of the
pulmonary veins no sugar is found. There is an exception to this
observable after a full meal, rich in starch and sugar, which produces
such an excess of glycogen that a portion is carried to the kidneys
and expelled by them causing temporary glycosuria.
A small amount of glycogen is also produced habitually by the
white blood cells and stored up in them, but this is insufficient to
determine its appreciable elimination by the kidneys.
In cases of persistent glycosuria the fault may be held to consist in
one of three functional derangements:
1st. The failure of the liver to transform the alimentary sugar into
glycogen.
or 2d. The excessive production of glycogen in the liver.
or 3d. The arrest of the destructive oxidation of sugar in the lungs
and tissues.
In a diabetic patient who died suddenly of apoplexy Bernard found
that the liver was enlarged, comparing with the average as 25:14
while the contained sugar bore the ratio of 37.5:22. This enlargement
coming from malaria or other poison, such as alcohol, ether (Harley),
arsenic, quinia (Aitken), ammonia, chloroform, or phosphoric acid
(Murchison), is an established condition of glycosuria. A rich and
abundant food (starchy and saccharine especially), or an unusually
active hepatic circulation acts in the same way.
Bernard as early as 1849 showed that the glycogenic function of
the liver was greatly increased and glycosuria determined by pricking
the floor of the fourth ventricle in the median line just in front of the
calamus scriptorius and near the root of the vagus nerve, or a few
millimeters in front of this.
It follows that irritation of this part of the medulla however
produced, whether from local disease, or by reflex action from some
distant organ in a state of irritation, may serve as the starting point
of diabetes in particular instances. That the cause may be a reflex
stimulus is shown by the suspension of the glycogenic function after
section of the vagus nerves, and its reappearance when the central
end of the cut vagus is galvanized, or, the floor of the fourth ventricle
is irritated, the direct or efferent excitation being transmitted
through the sympathetic nerve (Bernard). I can cite a case of
glycosuria in a man supervening on a severe blow on the head from a
falling ledger. Brain injuries which suspend animal functions, but
not the nutritive ones, such as apoplexy, concussion of the brain or
curare poisoning are liable to induce diabetes.
Traumatic injuries to other parts of the nervous system induce
glycosuria. Thus traumatism of the optic thalami; of the cerebral
lobes or peduncles; of the pons; of the cerebellum or of its middle or
posterior peduncles; transverse section of the medulla or of the
spinal cord opposite the second dorsal vertebra; traumatism of the
superior or inferior cervical ganglion or the first thoracic (Eckhard);
of the sympathetic twig which accompanies the vertebral artery
(Pavy); of the brachial plexus; of the solar plexus (Munck, Klebs); or
of the sciatic nerve (Schiff).
The explanation of these facts may be sought in a reflex action
established by the conveyances of irritation to the true glycogenic
centres in the brain and the transference of the efferent nervous
impulse through the sympathetic nerve to the liver. It will be borne
in mind that in the case of section of the vagus nerve electric
stimulation of its detached peripheral part has no glycogenic effect
on the liver, while galvanizing the central portion determines
glycosuria.
In the case of glycosuria through stimulation of the sympathetic
nerve or its ganglia the action may be concluded to be direct.
Strangely enough, irritation of the sympathetic between the tenth
and twelfth ribs or the splanchnic nerves fails to produce glycosuria,
though the hepatic branches of the sympathetic pass through them.
In ordinary cases of reflex glycosuria it may be assumed that the
existence of irritation at the peripheral ends of the vagus and of some
other nerves, leads to an apparent glycogenic influence passing
through these to the brain, and of the distribution of the efferent
impulse through the upper portion of the spinal cord, as far as the
fourth dorsal vertebra in the rabbit (Cyon, Aladoff, Schiff), and
through the sympathetic nerve to the liver. This may account for the
appearance of the disorder as a sequel of disease in any part to which
the vagus in particular is distributed, and notably in the lungs. A
number of poisons (malarial, alcoholic, ether, carbon monoxide,
amyl nitrate, curare, or the nitro-propionic acid, methyl delphinin,
morphia, chloral hydrate, arsenic, quinia, ammonia, chloroform,
phosphoric acid, and phlorizin) produce glycosuria.
The intravenous injection of dilute saline solutions, or frequent
blood letting materially increases the sugar, probably by causing
solution of the red globules. Phlorizin is the most potent of all these
agents. Whether given hypodermically or by the stomach it causes in
three hours a marked production of glucose which continues to be
eliminated for a period of thirty-six hours. The urine may become
charged with glucose to the extent of from 6 to 13 per cent., and
without any rise in the body temperature. This artificial glycosuria
may be kept up indefinitely by the continued administration of
phlorizin, and even in the fasting animal, or one on an exclusively
albuminous diet, as well as in those on an aliment rich in saccharine
or hydro-carbonaceous matter. In the frog it produces diabetes even
after the extirpation of the liver showing that it stimulates other
sources of sugar production beside the hepatic or that it inhibits the
transformation of sugar derived from the alimentary canal and other
sources.
Another suggestive source of mellituria is disease of the lungs, or
any condition which interferes with the due æration of the blood and
oxidation of the alimentary or hepatic sugar. But it cannot be
assumed that the rôle is altogether or mainly chemical. The thoracic
organs being supplied by branches of the vagus and sympathetic
nerves there is the obvious suggestion of a reflex action through the
diabetic centers in the brain. The frequent complication of diabetes
with lung diseases (inflammatory, tubercular, syphilitic, and
otherwise) is abundantly proved, whether it is to be explained on the
above hypothesis or through other unknown changes in the blood.
Diabetes has been repeatedly found in connection with disease of
the pancreas, and the complete extirpation of the pancreas in dogs
gives rise to glycosuria (Mering and Minkowski, Thiroloix,
Lancereaux, Lepine). If a small portion of the pancreas remains
glycosuria does not supervene. It has been suggested that the
pancreas has a double function, and beside its secretion, produces a
glycolytic ferment which passing into the portal blood determines
the formation of glycogen in the liver. Arrest of the pancreatic
secretions does not cause glycosuria, so it has been suggested that
the glycogenic enzyme is a product of the connective tissue cells of
the pancreas. Functional as well as structural disease of the pancreas
can be conceived of as inhibiting the production of this ferment and
the consequent elaboration of glycogen. Chauveau and Kauffmann
deduce from their observations that the action is a reflex one
established through the glycogenic centres in the medulla. Pancreatic
glycosuria is especially fatal (Harley).
Finally extirpation of the thyroid body in dogs has been followed
by glycosuria (Falkenberg). This suggests a systematic examination
of the urine in all cases of goitre, with extensive glandular changes.
Apart from experimental cases diabetes in the lower animals has
been observed to be nearly always associated with diseased liver.
Fatty degeneration has been the most frequent lesion, but cirrhosis,
hypertrophy and congestion were present in other cases. In a
number of cases as the fatty degeneration reached an extreme
degree, the sugar disappeared from the urine, the hepatic cells being
no longer functionally active, and death speedily followed. The same
has been observed in the fatty degeneration attendant on poisoning
by arsenic or phosphorus.
GLYCOSURIA IN SOLIPEDS.

Heiss records two cases of this disease in heavy Belgian horses ten
and eleven years old, the urine of which showed a percentage of 3.75
of grape sugar, and which died in two months in a state of
marasmus. The liver was enlarged and of a clay yellow color.
Dieckerhoff reports one fatal case in which there were also yellow
discoloration, congestion and hypertrophy of the liver. No lesion
could be found in the pancreas nor nervous system. Perosino records
a case in a horse suffering from contagious adenitis, which may be
supposed to have been connected with the action of the toxins or the
imperfectly oxidized albuminoids on the nerve centres or liver.
Delprato relates six cases in the same stable in overworked, half
starved and emaciated horses. Rueff and Mouquet each contributes a
case occurring in paraplegia attendant on hæmoglobinuria and in
which the amounts of sugar were respectively 5.85 and 1.01 per cent.
These latter cases are manifestly complicated ones in which the
reflex irritation (or inhibition of glycogenesis) is transmitted from
the diseased or poisoned brain to the already disordered liver.
Symptoms. There is a profound interference with nutrition, a
rapid loss of flesh and weight, of spirit and energy and an extreme
muscular weakness in spite of an excessive appetite. The subject is
fatigued and breathless under the slightest exertion, the flanks are
retracted and hollow, and the hair dry, rigid and lifeless. Appetite is
poor and fastidious, but an intense and consuming thirst is usually
present, the animal drinking deeply at every opportunity, and
passing urine with corresponding frequency and abundance. The
urine is clear, yellow, neutral, and saccharine, the sugar varying from
1 to 12 per cent. (3.6 on an average). Notwithstanding the amount
passed (55 litres per day, Cadeac) the density usually exceeds the
normal (1052 and upward), normal being 1040 to 1050. There may
or may not be hyperthermia, and in exceptional cases appetite has
been retained to the last. Cataract and corneal ulceration are
sometimes observed as in man.
Diagnosis. Presumption may arise from the above mentioned
symptoms, and especially the bulimia, the polydipsia, the polyuria,
the rapidly advancing emaciation, weakness, and prostration and the
ocular troubles, but conclusive evidence is only found in the presence
of glucose permanently in the urine.
Tests for Sugar in the Urine. For one who can go through it the
touching of the tip of the tongue with a drop of the suspected urine
will give a prompt and reliable test.
Fehling’s cupric test is the next best for simplicity and availability.
Dissolve 34.639 grammes (1⅕ oz.) pure cupric sulphate in 200 cubic
centimeters of distilled water: 173 grammes (6 ozs.) of pure neutral
sodio-potassic tartrate and 80 grammes of potassium hydrate in 500
cubic centimetres of distilled water. Add the copper solution slowly
to the potassium one and dilute the clear mixture to one litre. One
cubic centimeter of this fluid will be discolorized by 0.005 gramme of
sugar; or 200 grains will be discolorized by 1 grain of sugar.
Trommer’s test is even simpler for a mere qualitative test. Pour the
suspected urine, freed from albumen, into a test tube and add a
solution of caustic potassa or soda until distinctly alkaline. Should
this throw down earthy phosphates or carbonates filter these out.
Then add drop by drop a solution of pure cupric sulphate in distilled
water (3.5:100) so long as it throws down a yellowish red precipitate
of oxide of copper. When the supernatent liquid remains clear and
assumes a distinctly bluish tint, the sugar has all been precipitated.
The amount of precipitate is a criterion of the quantity of sugar,
which may be otherwise estimated by the amount of copper salt
used.
The fermentation test is made by adding a teaspoonful of liquid
yeast to four ounces of the suspected urine, stopping the flask lightly
and placing it in a temperature of 60° to 80° F. for 12 to 24 hours
when the sugar will have been converted into alcohol and dioxide of
carbon. The loss of weight will indicate the amount of sugar, as also
will the lowering of the specific gravity. If before testing the urine
was 1060, and after 1035, it contained 15 grains of sugar to the fluid
ounce.
Prognosis. This is always rendered more grave in the horse than in
man, because of the impossibility of putting him on a purely
albuminous diet. The great tendency is to a rapidly fatal issue,
especially in cases of irremediable structural lesions in the brain and
liver. Where the disorder is largely functional, as in connection with
hæmoglobinuria or as the result of poisons ingested the prospect of
recovery is often good.
Treatment. In cases due to poisoning the use of antidotes and
eliminating agents will be effectual, and in transient and curable
diseases like pulmonary disorder, hæmoglobinuria and paralysis the
appropriate treatment will restore. In the more inveterate or
constitutional cases all treatment is liable to prove ineffectual. At the
outset some apparent amelioration may be obtained from salicylic
acid, salicylate of soda, bicarbonate, acetate, citrate, sulphate or
chloride of soda, nitro-muriatic acid and other cholagogues. Blisters
to the perichondrium may also be employed. Later, when
degeneration of the liver has reached an extreme point, these will be
of no avail. Cadeac recommends acetanilid, antipyrine, and benzo-
naphthol largely on their antiseptic merits, and Jong claims a
recovery in a horse under daily doses of 12 grains of codeine. Opium
has long been employed in man with partially good results, and
croton chloral, strychnia, phosphoric acid, iodoform and ergot are
recommended in different cases.
One of the most beneficial agents is skim milk or buttermilk as an
exclusive diet, and this may be to a large extent adopted for the
horse. Under its use the sugar may entirely disappear, and though
rheumatoid pains in the joints may be brought on, these usually
subside on withdrawing the source of lactic acid. They may further be
met by the use of salicylates. The greatest care should be taken of the
general health, an open air life, with protection against colds and
storms, and a healthy condition of bowels, kidneys and skin being
particularly important.
The impaired digestion and assimilation usually demand
carminatives, stomachics, bitters, and mineral acids, particularly the
nitro-muriatic. With the same intent a fair amount of exercise short
of absolute fatigue should be secured. But each case will require a
special study and treatment consonant to its special attendant
lesions, its causative functional disorders, and its stage. One case
may demand attention to bacteridian poisoning, one to a better
regimen and diet, one to liver disease, and one to disease of the
brain, etc. After this treatment specially directed to the abnormal
function or structure, would come the more specific treatment for
mellituria which would be more or less applicable to the general
glycolytic disorder.
GLYCOSURIA IN CATTLE.

Accompaniment of parturition fever and apoplexy. Essential glycosuria. Dense


saccharine urine, passed often, congested mucosæ, emaciation. Lesions uncertain.
In parturition fever and apoplexy the congested medulla is the reasonable starting
point. Toxic glycosuria. Treatment: addressed to the primary disease or poison;
otherwise treat as in the horse.

In cattle this has been observed as a symptomatic affection in


connection with parturition fever or apoplexy (Nocard, St. Cyr,
Violet). One case of essential mellituria has been recorded by Darbas.
Symptoms. In the last mentioned case in a work ox, the animal,
when at work, would stop every five or ten minutes to urinate,
passing a small quantity of amber colored urine of a high density and
containing a large amount of glucose. The conjunctiva was pink, the
animal considerably emaciated, and rest and generous feeding
brought about no improvement, so that the subject was finally sent
to the butcher to anticipate a natural death.
The lesions in this case are altogether hypothetical. The red eyes
might imply congestion of the encephalon (medulla), but the redness
might be caused by active disease in the liver, pancreas or kidney.
The failure to notice jaundice does not indicate a healthy liver, as
some of the most fatal diseases of that organ are unattended by
icterus. The frequent emission of urine in small amounts would
imply irritation in kidneys or bladder, from which the glycogenic
stimulus may have started. In the absence of any more definite
evidence of disease in other organs it is, however, more probable that
the fundamental disorder resided in the liver, the great glycogenic
factor of the body.
In parturition fever, the presumption is in favor of considering the
congested medulla as the starting point of the disease, yet in view of
the manifest paralysis of stomach and bowels, it is not improbable
that the vascular congestion and paralysis of the chylopoietic viscera
constituted the initial step in the morbid process, while the
glycogenesis was the result of a reflex operation on the liver.
Toxic mellituria would occur in cattle under the same conditions
as in the horse.
Treatment is only hopeful in the sympathetic and toxic forms.
These must be treated according to the nature of the primary disease
or the poison. To these the general principles of treatment as
recommended for the horse should be superadded. For essential
diabetes an exclusively milk diet and any one of the agents that have
given good results in man or horse can be tried, but with an animal
in fair condition it will be better as a rule to turn him over to the
butcher.
GLYCOSURIA IN THE DOG.
More common than in horses and cattle. Causes: pampered in diet, sweets, liver,
disease of pituitary body, or mostly of the liver. Removal of pancreas. Brain and
nervous lesions and reflex action. Symptoms: pampered asthmatic subject, with
dysuria and lameness, dense, saccharine urine, bulimia, loss of weight, corneal
ulcers, cataracts, palsy, coma. Duration: 4 to 8 months, sugar may disappear with
complete liver degeneration. Diagnosis: by pampered condition, asthma, thirst,
diuresis, later by loss of weight, troubles of vision, saccharine urine. Lesions:
usually hypertrophied, fatty or caseated liver, thickened capsule, disease of thyroid,
heart and eye. Treatment: skim or butter milk as sole diet, restricted diet of lean
meat clear of fat, warmth, dryness, pure air, sunshine, gentle exercise only,
cholagogues, sodium sulphate, or chloride, or carbonate, or salicylate, salol, nitro-
muriatic acid, antithermics, ergot, codeine, bitters, mineral acids, derivatives.
Among domestic animals the dog has furnished the greatest
number of cases, yet even in this animal the disease appears to be far
from common.
Causes. The relative frequency of diabetes in the dog is probably
dependent on his life in human dwellings and on gourmandizing on
dishes prepared for man. Friedberger and Fröhner have produced
the disease artificially by feeding a great quantity of sugar and W.
Williams has met the disease in dogs fed exclusively and generously
on liver. Thiernesse records one case complicated by atrophy and
steatosis of the pituitary body, but in all other instances the
appreciable lesions were confined to the liver. In one case, reported
by St. Cyr, the liver was hypertrophied, yellow, mottled, marked by
irregular elevations of congested and hypertrophied hepatic tissue,
and showing extensive degeneration—mucous, caseous and fatty.
Thiernesse found the liver of a yellowish white color, and the seat of
fatty degeneration implicating the hepatic cells. Franzenberg in one
case found fatty degeneration of the liver, and Fröhner and
Schindelki, in four cases, met with extensive hepatic disease. The
macroscopic lesions of the disease in dogs as in horses appear to be
mainly hepatic.
On the other hand the complete removal of the pancreas in the dog
by Mering, Minkowski, Thiroloix, Lancereaux and others was
invariably followed by mellituria, so that even in the absence of
clinical examples, we must recognize pancreatic lesions and
functional disorders as possible primary causative factors in
glycosuria. In the light of experimental medicine we must similarly
recognize brain and nervous lesions and reflex actions as possible
causes, even if as yet unsupported by clinical facts observed in the
dog.
Symptoms. The disease usually appears in an old, fat, pampered
dog, affected with dyspnœa or asthma, with dysuria and lameness.
The urine is high colored, viscid, and of a high density (1055 to 1060,
the normal canine urine being about 1020), and charged with
glucose. The subject may have an enormous appetite but fails to gain
in weight, and after a time loses flesh and becomes badly emaciated.
The pulse is small and frequent, and the temperature which at the
outset may reach 102°, falls to the normal as the end approaches.
Watering eyes, corneal ulcers, and cataracts as well as hemiplegia
and diabetic coma may precede death. The amount of sugar has been
found to vary in different cases from 3.2 to 12 per cent. of the urine.
Course. Duration. The dog may live from four to eight months
and, as in the horse, sugar may finally entirely disappear from the
urine, in connection with the progressive degeneration of the liver. If
the patient is unable to take exercise, the case reaches a more
speedily fatal issue.
Diagnosis is deduced from the bulimia, pampered condition,
breathlessness, thirst, and diuresis, the subsequent loss of condition,
ocular troubles, and dropsy or coma, the whole being confirmed by
the dense, high colored, viscous, saccharine urine.
Lesions. As already noticed the most constant lesion is
hypertrophy of the liver, which is swollen unevenly, has thickened
borders, is yellow or red, very friable and often fatty, or caseated. The
capsule of Glisson is thickened and fibrous. Hypertrophy and fatty
degeneration of the thyroid have been found in different cases and in
one instance insufficiency of the mitral valve with systemic venous
congestion. Ocular troubles are constant.
Treatment. Put the patient on an exclusive diet of skim or butter
milk or if this is impossible it may be conjoined with lean meat—raw
or cooked—keep warm and dry, but give plenty of open air and
sunshine. Avoid fatigue and over exertion. Restricted diet is of great
importance. During the siege of Paris the short rations led to the
disappearance of glycosuria from many human patients.
Among medicinal agents, cholagogues come first, sulphate of soda
with chloride of sodium, bicarbonate of soda, salicylate of soda, salol,
nitro-muriatic acid, may be named. For the febrile condition,
antipyrine, acetanilid, or phenacetin may be employed, and
iodoform, ergot or codeine may be tried when other measures fail.
Bitter tonics and mineral acids may be beneficial, and lastly blisters
to the region of the liver may prove of service.
OBESITY AND EMACIATION.
Sugar essential to growth. Ratio of liver to active increase in weight. Obesity and
fatty degeneration. Small inactive liver and stunted growth, or loss of weight.
Biliary fistula, death in 12 months. Influence of pancreas. Nitrogenous food for
obesity, outdoor life, exercise, cholagogues, salines. Saccharine and starchy food
for emaciation, hepatic, and pancreatic stimulants. Mild laxatives and cholagogues,
pure air, green, succulent food, pure water, bitters, tonics, moderate exercise.
There is reason to believe that both of these occur as results of
hepatic disorder. The generation of sugar in connection with rapid
cell growth in germinating seeds and growing plants, and also in
rapidly growing animal tissues as in the body of the fœtus and fœtal
membranes, and finally in the inflammatory products of pneumonia
and in leucocytes, seems to imply that it is essential to such cell
growth (Murchison). In keeping with this is the fact that the liver is
of relatively much greater size in the fœtus and in the young and
rapidly growing animal, and also in meat producing animals which
have been selected and bred through many generations for early
maturity and rapid fattening. The enormous development of adipose
tissue and of lipomata in such animals is essentially abnormal,
though it is a deviation from the natural that is esteemed as evidence
of excellence, and a necessary condition of success in the meat
producing industry. While other conditions are necessary to the
production of such obesity, such as abundance of rest, slow, shallow
breathing, a genial climate, and a generous hydro-carbonaceous
food, yet all of these would prove ineffective without a large liver,
working under high pressure in producing a large output of sugar.
The mere obesity in the meat producing animal is not considered as
disease and it is only when the tendency to fat production culminates
in an adipose degeneration of the muscles and other tissues that
actual disease is conceded.
Emaciation in certain cases is traceable to the opposite condition.
A small or inactive liver with a diminished production of sugar and
fat will ensure loss of weight, which is still further aggravated by
decreased secretion of bile and insufficient absorption of peptones.
Experimentally this condition has been repeatedly brought about by
making a biliary fistula, and cutting off all bile from the intestine.
Death preceded by extreme emaciation ensues in 12 months
(Murchison). This being the case with the escape of all the bile
secreted, a slower but no less certain emaciation must follow on a
structural or functional disorder of the liver which is attended with a
greatly lessened production of bile. This, indeed, is the condition met
with in advanced glycosuria, when the liver is the seat of general fatty
degeneration.
From the experiment of the removal of the pancreas we may infer
that diseases of this organ which pervert or destroy its normal
functions, will check glycogenesis in the liver by withholding the
supposed pancreatic ferment, and by so doing will conduce to
emaciation and marasmus.
So far as obesity and emaciation are dependent on diet they may
be checked by subjecting the patient to the dietary which will favor a
more healthy liver function. For excessive obesity a strictly
nitrogenous food in restricted amount will tend to lessen the
glycolytic action of the liver and secure the formation of muscle
rather than fat. An outdoor life, and an active though not exhaustive
use of the muscles will greatly favor this result. For the carnivora or
omnivora a diet of lean meat or skim milk might be employed, while
for the herbivora, wheat bran, cotton seed hulls, beans, peas, vetches,
or cotton seed would measureably meet the demand. Cholagogues
and saline laxatives, by eliminating from the liver and intestine, will
contribute to the same end.
If emaciation depends on a deficiency of sugar, that may be freely
fed along with richly amylaceous food, and the liver may be
stimulated to increased glycogenesis, by stimulants such as
chloroform, ammonia, or ether, and by a moderate use of carbonate
of soda or other alkalies. Ether has in addition a stimulating effect on
the pancreas and will tend to increase that ferment which stimulates
the liver to its glycogenic work. Mild laxatives and cholagogues will
second this, such as small doses of podophyllin, taraxacum, nitro-
muriatic acid, chloride or bromide of ammonium, plenty of pure air,
abundance of green or aqueous food, and plenty of pure drinking
water. Finally moderate exercise, by increasing the aspiratory action
of the chest and thereby accelerating the hepatic circulation is a
material stimulant of the glycolytic function. Bitter and other tonics
are contributions to the same object and should not be neglected.

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