Which of eight sources controls a disputed-debt settlement? AC566's Unit 2 authority hierarchy exercise puts the Code first and a circuit reversal above the Tax Court. Searches like "ac 566 unit 2 assignment example", "ac566 unit 2 sample" and "ac566 unit 2 example" land here.
What a finished AC566 Unit 2 authority hierarchy exercise looks like
A ranked table of eight rows followed by a page of explanation. Every row gives the source, its type, the body that issued it and one sentence on its weight. Section 61(a)(11) and Section 108(e)(5) sit at the top. Treasury Regulation 1.61-12 comes next, with a note that since Loper Bright Enterprises v. Raimondo in 2024, courts no longer defer to an agency's reading of an ambiguous statute simply because it is reasonable. The Third Circuit's 1990 decision in Zarin ranks above the Tax Court decision it reversed, because the client's appeal would lie to that circuit. A revenue ruling follows, then a private letter ruling that Section 6110(k)(3) bars as precedent, then a treatise chapter and a practitioner blog, labeled as finding aids only.
How a AC566 Unit 2 example is structured
The ranking follows two principles stated at the outset: primary authority outranks secondary, and within primary authority the issuer and the forum decide weight. The statute leads because everything else interprets it. The regulation follows, and the exercise explains how its standing has shifted since Chevron deference ended without overstating the change: final regulations still bind the IRS and remain heavily persuasive in court. Judicial authority is ranked by forum. Under the Golsen rule the Tax Court follows the law of the circuit to which a case is appealable, so for a client resident in New Jersey the Third Circuit's reversal controls over the Tax Court's own opinion. Administrative guidance comes next, a revenue ruling placed above a private letter ruling for a stated reason. Secondary sources close the table, each described as a route to authority rather than authority itself.
Primary before secondary
Two principles are stated before the table, so every placement can be tested against them rather than accepted on the writer's word.
Statute and regulation
Sections 61(a)(11) and 108(e)(5) head the list, Regulation 1.61-12 sits below them, and a sentence explains what Loper Bright changed in 2024.
Forum decides the court ranking
Golsen makes the Third Circuit's reversal in Zarin controlling for a New Jersey taxpayer, even though the Tax Court opinion sits closer to the dispute.
Rulings of unequal reach
A published revenue ruling binds the IRS and may be relied on by taxpayers with similar facts; a private letter ruling binds only its recipient.
Finding aids, labeled as such
A treatise chapter and a practitioner blog are ranked last and marked as useful for locating authority, never as support for a conclusion.
Where marks go in AC566 Unit 2
The exercise is typically marked on reasons more than on order. A correct sequence with no explanation shows memory, not judgment, and earns partial credit at best. Placing the Tax Court above a circuit court without asking where the client would appeal is the error the fact pattern invites, and it recurs. Treating a private letter ruling as precedent, despite the statutory bar, is close behind. Some papers still describe regulations as receiving Chevron deference, which dates the analysis to before 2024; others overcorrect and call regulations merely advisory. Secondary sources ranked above administrative guidance, because the treatise explained the issue better, confuse clarity with authority. A table that omits each source's issuer and date leaves the reader unable to verify it, and placements defended with no citation cost further points.
Get a AC566 Unit 2 example written to your instructions
The source list and fact pattern from the Unit 2 assignment, the client's state where the prompt names it, and the rubric get this started. Every source is ranked with its issuer, date and a reason for its placement, with forum rules applied where they decide the order. It takes 24-48h, and your first sample is free.
AC566 Unit 2 questions, answered
Why does the client's state matter to the ranking?
Because it determines the circuit to which a Tax Court decision would be appealed, and under the Golsen rule the Tax Court follows that circuit's precedent. A New Jersey resident's case goes to the Third Circuit, where Zarin controls. The same eight sources, ranked for a client in another circuit, would place Zarin as persuasive only, and the example says so in a note beneath the table.
Did Loper Bright make regulations less important?
Less deferred to, not less important. The 2024 decision ended Chevron deference, so a court now decides for itself the best reading of an ambiguous statute rather than accepting a reasonable agency view. Final regulations still bind the IRS, still carry substantial weight, and many rest on express delegations Congress wrote into the Code. The example ranks the regulation second and explains that nuance in two sentences.
Can a private letter ruling be cited at all?
It can be cited as evidence of the IRS's reasoning, but Section 6110(k)(3) says it may not be used or cited as precedent. The example ranks it low and labels it that way. For substantial authority purposes under the penalty regulations, private letter rulings issued after October 1976 are listed among the sources that count, which the example notes as a point separate from precedent.