The preceding section states that the regulations and sections listed will determine whether the “gross income” of an individual is derived from a taxable source of income. 26 CFR § 1.861-8(a)(4) Statuory grouping of gross income and residual grouping of gross income. For purposes of this section, the term "statutory grouping of gross income" or "statutory grouping" means the gross income from a specific source or activity which must first be determined in order to arrive at "taxable income" from which specific source or activity under an operative section (Emphasis added) ‘An examination of the source of my client’s income must be performed prior to any determination as to whether the client has faxable “gross income” and po: itty, 26 CER § 1.861-8(f) states: (B) Miscellaneous matters -- (1) Operative sections. The operative sections of the Code which require the determination of taxable income of the taxpayer from specific sources or activities and which give rise to statutory groupings to which this section is applicable include the sections described below. ‘The sections describing taxable income from within the United States lists the following sources: i, Overall limitation to the foreign tax credit. ii, [Reserved] iii, DISC and FSC taxable income iv Effectively connected taxable income. Nonresident alien individuals and foreign corporations engaged in trade or business within the United States, Foreign base company income. vi. Other operative sections. a) foreign source items of tax... @) foreign mineral income... © [Reserved] ) “.. foreign oil and gas extraction income...” ® “...citizens entitled to the benefits of section 931 and the section 936 tax credit...” © “...Residents of Puerto Rico...” (@) “...ineome tax liability incurred in the Virgin Islands...” ®) “.,.income derived from Guam...” @ “...China Trade Act corporations...” @ “...income of a controlled foreign corporation...” « “...ineome from the insurance of U.S. risks...” «) “.,.intemational boycott factor...attributable taxes and income under section 999...” ™) income attributable to the operation of a agreement vessel under section 607 of the Merchant Marine Act of 1936...” Specifically, from which of the above listed taxable sources of income is my client’s “gross income” derived? If it is none of the above, please so state. If there are other taxable sources of income, I am unaware of them, Please provide a detailed list, including code and regulation citations of any taxable sources from which you believe my client may have received income.In reviewing the documents sent by the IRS, I do not find any citation or reference to the particular tax for which you are claiming my client, [client], has a liability. What forms, records or regulations did the IRS use to determine [client] has a tax liability? This is a Privacy Act request asking for these records. Since there are numerous types of taxes enumerated in the Internal Revenue Code, I need to know the particular tax or taxes, as well as the years in question, for which the IRS has determined my client has an alleged tax liability. 1 also need to know what specific tax form(s) the IRS records claim or show [client] was required to file for the specific year or years in question. Specifically, the documents I need you to send are: 1) The documents that evidence the taxable source of income applicable to [client] as per 26 CER 1.861-8. 2) The documents that evidence the particular tax for which [client] is liable. 3) The documents that evidence the particular form [client] is required to file for that tax.