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INTRODUCTION

Federal tax authority is comprised of both primary and secondary sources.  The government's legislative, administrative and judicial branches produce primary authority in the form of statutes, treaties, regulations, rulings and judicial decisions.   As with other areas of research, it is important for the tax researcher to understand the functions of these governmental bodies and the sources of law promulgated in their capacities.  Secondary sources of tax authority consist of unofficial publications, such as treatises, tax services, and periodical literature.  Secondary tax materials are created to locate, explain, analyze and interpret primary tax resources.  By understanding these basics, the task of finding print and electronic resources that publish these materials becomes a systematic and methodical procedure facilitating the tax research process.

This research guide takes a bibliographic approach to federal tax research and explains how and where to find tax documentation.  Indicated call numbers are specific to locations within the Georgetown Law Library at Georgetown University Law Center.

A. HOW TO BEGIN YOUR TAX RESEARCH

When in doubt, consult a research guide.  There are a number of tax research guides and textbooks available that explain the fine points of tax research.  More importantly, research guides are useful tools as they reveal the appropriate publications where tax documentation can be found.  Loose-leaf services are also good places to begin with, as they compile both primary and secondary materials in one place.  The following sources are but a few helpful reference sources available from the EBW Library tax collection.

1. TAX RESEARCH GUIDES

a. Jacobstein, J. Myron, Fundamentals of Legal Research.  [KF240.J322 2002] See chapter 24 on Federal Tax Research.

b. Karlin, Barbara, Tax Research. [KF241.T38 K37 2000]

c. Raabe, Whittenburg, & Bost, West's Federal Tax Research.  [KF241.T38 R33 2003]

d. Richmond, Gail, Federal Tax Research: Guide to Materials and Techniques. [KF241.T38 R5 2007]

e. Chanin, Leah F., Specialized Legal Research [ KF240 .S64 ]

f. Larson, Joni & Sheaffer, Dan, Federal Tax Research [KF 241 .T38 L37 2007]

g. Tax Cite: A Federal Tax Citation and Reference Manual, American Bar Association Section of Taxation. [KF245 .T39 1995]

h. Smith, Robert Sellers, West's Tax Law Dictionary. [ KF6287 .S65 1993]

i. Tax Reference Chart - www.ll.georgetown.edu/guides/fedtax_chart.cfm
Georgetown's Tax Reference Chart is a useful guide that reveals print and electronic resources for tax materials.

2. TREATISES

Tax treatises are great starting points.  They offer expert tax analysis and often cite to and reprint primary tax documentation.  The Georgetown Law Library's Treatise Finder specifically identifies tax treatises. To find additional tax treatises in the the EBW library, perform a word search using the library's online catalog, GULLiver.  Once a relevant record is located, use that record's subject headings to find more relevant book records. 

3. LOOSE-LEAF SERVICES

Loose-leaf services are hybrid research tools that bring together both primary and secondary materials.  These compilations provide access to statutes, regulations, and excerpts from Congressional reports, administrative rulings, references to judicial decisions and other official documentation. Loose-leafs also provide analysis and practical explanations for complex tax issues.  Loose-leaf services are great finding aides as they offer sophisticated indexing and finding lists.  The advantages of these services are further expanded by the availability of companion sets that report tax cases and agency actions.  As many loose-leafs are updated weekly to biweekly, they offer information that is often more up-to-date than other print sources.

When using any loose-leaf for the first time, it is wise to review the "How to use" or "About this publication" pages explaining the scope and proper usage of the set.  Listed below are references to major tax loose-leafs services.

a. Standard Federal Tax Reporter, CCH. [KF6365.C58]
Updated weekly, the Standard Federal covers federal income tax laws and is situated in a twenty-five volume set arranged by code section.  Access into the set is accomplished in a number of ways; keyword searches using the topical index, scanning the spine label for the appropriate code section range when a specific code section is predetermined, or by referencing finding lists and citator volumes with a known case name. Also available electronically through the CCH Tax Research Network. [Subscription database (GULC only)]

b. United States Tax Reporter, RIA [ KF6280.P7 1992]
Within its eighteen volumes, the United States Tax Reporter covers income, estate, gift, excise, and employment tax issues and is arranged by code section.  Access to the set is made possible by conducting keyword searches using the sets' topical index volume.  If the researcher has a code or regulation citation, it is also possible to scan the spine labels for the appropriate code section range leading to the text of the code or regulation.  Case name searches are made possible by using the sets' citator volumes and finding lists that provide access to the appropriate volumes. Also available through Checkpoint, RIA. [Subscription Database (GULC only)]

c. Federal Tax Coordinator 2d, RIA [ KF6285.F4] Also available through Checkpoint, RIA [Subscription Database (GULC only)]
The Federal Tax Coordinator is arranged by subject matter and covers income, gift, estate and excise taxes.  This set is comprised of twenty-eight volumes that are updated weekly.  This service offers a number of Indices and finding lists as access points into the compilation volumes.  Access is possible through a number of methods.  Keyword searching is possible by using the Index volume.  Another method is by scanning the spine labels for the appropriate topic.  It is also possible to use the sets' "Finding List" when searching with a known case name, code section, regulation, or ruling citation. Also available through Checkpoint, RIA. [Subscription Database (GULC only)]

d. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5] Also available through Westlaw [Subscription Database (GULC only)]
Merten's Law of Federal Income Taxation is a subject arranged loose-leaf that covers income tax provisions only.  Much like other loose-leafs, Merten's presents the Code in relation to its correlated regulations and rulings.  In addition, Merten's provides detailed commentary and analysis of tax issues.  Researchers can use Merten's Index to perform subject searches for information when only keywords are known.  Code, regulation, rulings and case tables are available to locate known citations or cases within the text of the loose-leaf. Also available through Westlaw.

e. Federal Estate and Gift Tax Reporter, CCH. [KF6571.A8 C58 1983]
A companion set to the Standard Federal, the Federal Estate and Gift Tax Reporter covers estate, gift, and generation-skipping transfer tax laws.  This three volume loose-leaf is arranged by code section and offers three ways to access the information inside.  Keyword searches can be conducted using the Cumulative and Topical Indexes.  Case name searches are possible examining the Citator Case Table.  Citations are easily found using the set's Finding List. Also available electronically through the CCH Tax Research Network. [Subscription database (GULC only)]

f. Federal Excise Tax Reporter , CCH. [KF6600.A6 C62]
This loose-leaf explains federal excise tax and is arranged by code section order and related committee reports, regulations, rulings, and CCH explanations. Also available electronically through the CCH Tax Research Network. [Subscription database (GULC only)]

g. Tax Management Portfolios, BNA. [KF6297 .B952]
Arranged topically, Tax Management Portfolios are divided into three broad topic areas; Federal income taxation (red), estates, gift and trust taxation (green), and foreign income taxation (blue), each area is designated by a specific color.  Although not a loose-leaf in the truest sense, BNA offers over 300 spiral portfolios that provide detailed and thorough analysis of complex tax issues and includes working papers and bibliographies to additional resources.  The index volume, however, is updated in the loose-leaf format, as new portfolios are added and superseded portfolios are replaced.  There are four methods of approach offered as access points to the portfolios.  By topic, the researcher should use the classification guides located in the loose-leaf index volume.  By keyword, use the keyword index located in the index volume.  By Code section, the index volume also offers a code section index.  Within the index volume there is also an index where by researches can locate IRS forms and publication publications. Also available electronically from BNA's Tax Management Library. [Subscription database (GULC only)]

STATUTORY SOURCES

Statutory sources include the U.S. Constitution, tax treaties, and federal tax statutes known as the Internal Revenue Code (IRC, 26 USC).

A. U.S. CONSTITUTION

Art. I, sec. 8 of the Contitution authorizes the Congress to levy taxes. Tax bills must originate in the House of Representatives (art. I, sec. 7). Art. I, sec. 2 requires direct taxes to be apportioned according to population. Since the Federal income tax was held by the Supreme Court to be a direct tax (which was not so apportioned), the Sixteenth Amendment was adopted to allow income taxation without apportionment. Art. I, sec. 0, prohibits taxes on exports.

A number of provisions provide limitations on how taxing authority may be exercised by Congress or the States. Art. I, sec 10 prohibits state duties on imports or exports without the consent of Congress. The Commerce Clause (art. I, sec. 8) prohibits state taxation that burdens interstate or foreign commerce. The Fifth Amendment prohibits deprivation of property without due process. Equal protection of the law is guaranteed by the Fifth and Fourteenth amendments.

The Constitution can be found in volume one of the United States Code [KF62 2000.A2], United States Code Annotated [KF62 1927 .A3] and United States Code Service [KF62 1972.U5], GPO Access Website, Lexis, Westlaw , as well as many other commercial publications and databases.

B. TAX TREATIES

Tax treaties are agreements made between countries to mitigate the double taxation of those entities subject to the tax laws of both countries.

1. LOCATING TAX TREATIES

a. Internal Revenue Bulletin, US G.P.O. [KF6301 .A12]; issues from 1996 on also available electronically on the IRS home page (1996 - present).
The Internal Revenue Bulletin (IRB) is often the first place treaties are printed.  This source includes Executive Reports and Treasury Department technical explanations prepared for the Senate. When available, tax treaties and committee reports are located in part II.

b. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1]; 1995-2002 Cumulative Bulletin available electronically from the IRS home page.
The Cumulative Bulletin (CB) reprints treaty text and includes Executive Reports and Treasury Department technical explanations prepared for the Senate.  Tax treaties and committee reports are located in part II.

c. Federal Tax Coordinator 2d, RIA [KF6285 .F4 1984] also available through Checkpoint, RIA [Subscription Database (GULC only)]
Volume 20 contains the full text of treaties negotiated by the US and other countries involving income, gift and estate tax laws.Also available through Checkpoint, RIA. [Subscription Database (GULC only)]

d. Rhoades & Langer, US International Taxation and Tax Treaties, Mathew Bender. [KF6419.R48]
This six volume loose-leaf offers annotated text of every US income tax treaty currently in force.  Includes coverage of prior US income treaties and the text of every US estate and gift tax treaty.  Also available is the text of the Tax Information Exchange Agreement (TIEA) and transportation agreement currently in force.  This resource is also available through Lexis: Legal > Area of Law - By Topic > Taxation > Treaties & International Agreements > Rhoades & Langer U.S. International Taxation & Tax Treaties.

e. Tax Treaties, CCH. [KF6306 .C6]
Offers the full texts of Model treaties and U. S. treaties with foreign countries involving income and estate taxes.  The CCH Tax Treaty compilation is arranged alphabetically by country and includes regulations, annotations, Department of State reports, Senate Committee on Foreign Relations reports, Treasury Department and IRS rulings and relevant court decisions. Also available through the CCH Tax Research Network. [Subscription database (GULC only)]

f. Tax Treaties, Warren, Gorham & Lamont. [KF6306 .P7; current edition ONLINE ONLY through Checkpoint, RIA. (Subscription Database [GULC only].)]
Tax Treaties by Warren, Gorham & Lamont, is a three volume loose-leaf containing treaties negotiated between the US and foreign countries in the matters of income, estate and gift taxes.  This set provides the full text of treaties, an editorial explanation of the treaty, and the full text of any protocols.  Also available are background documents including diplomatic notes, State Department reports, Senate Foreign Relations Committee reports, Treasury technical explanations, Joint Committee on Taxation explanations, Assistant Treasury Secretary statements and any general and withholding regulations. The library stopped updating this set in 1997 and had it bound, however, the current edition is available electronically through Checkpoint, RIA.

g. Tax Management Portfolios, BNA. [KF6297 .B952]
Selected treaties are also available in the Foreign Income compilation of the Tax Management Portfolios.  To ascertain if a specific treaty is reprinted in the portfolios, locate the Foreign Income tab in the index binder.  Use the classification index to scan the index under the "Tax Treaty" heading.  It is also possible to locate treaties by examining the heading specific to the foreign country involved and locating the "Tax Treaty" subheading. Also available electronically from BNA's Tax Management Library. [Subscription database (GULC only)]

h. TIARA Online. [Subscription Database, (GULC only)]
Although not exclusive to the area of tax, TIARA provides full text of over 12,000 treaties and agreements, the earliest of which dates back to 1783.  It also contains Senate Treaty documents from 96-1 through the current Congress, and the US Department of State documents from DOS 86-1 to the present.

i. US International Tax Treaties of All Nations. Oceana Publications. [Int'l K4473.A1 I5] & Series B [Int'l K4473.A1 I57]
Contains English language texts of all tax treaties between two or more nations in force on July 1, 1975.  Series B contains tax treaties not yet published by the United Nations, printed in English and in the languages of many signatories.

j. Legislative History of United States Tax Conventions. Hein. [KF6306 .L43 1986r; last updated in 2006]
Provides access to legislative materials for those tax agreements to which the U.S. is a party, involving income, estate and gift tax.  Documents included within the multi-volume set are, treaty status tables, Senate documents, Senate Foreign Relations Committee Hearings and news articles.  This resource also includes the text of exchange agreements.

2. UPDATING TREATIES

a. Shepard's United States Citations. (Colorado Springs: Shepard's/McGraw Hill, 1996-) [KF153.2 .S5]. Pre-1950 treaties are listed by Statutes at Large number and after 1950 they are listed by UST or TIAS number. Provides citations to treaties that amend earlier treaties. Not available on Lexis.

b. Treaties in Force (TIF) (Washington, DC: Office of the Legal Advisor, U.S. Dept. of State, 1950-) [KZ235 .G84].  This annual publication lists and very briefly summarizes all U.S. treaties and agreements still in force, arranged by country and subject. Includes both bilateral and multilateral treaties and gives references to UST cites and TIAS numbers (if one exists). The primary use of TIF is verification of the existence of a treaty. TIF is also available on the Web from the Department of State Website, but the electronic version is no more current than the print.  Since TIF is only published once a year, use the electronic version of Treaty Actions to update TIF.  Archived Treaty Actions are also available on that site.  TIF is also available on Lexis (INTLAW/Treaties and International Agreements). Where possible, TIF on Lexis links to the text of the treaty.

c. Treaty Actions. Monthly publication on the Department of State web site that provides current information on the status of bilateral and multilateral treaties. Used to update TIF.

C. STATUTES (a.k.a. Internal Revenue Code, U.S.C. Title 26)

After the ratification of the 16th amendment in 1913, Congress passed a number of revenue acts.  These acts were periodically recodified until this task became too unmanageable.  In the 1930s, Congress passed the first fully organized federal tax law, known as the Internal Revenue Code of 1939.  The 1939 Act soon became too inflexible and so the Internal Revenue Code of 1954 was passed.  As part of the 1986 tax reform, the Internal Revenue Code of 1954 was renamed the Internal Revenue Code of 1986, as amended.  The 1986 tax code is the present law standing and can be found in the sources listed below.

1. LOCATING THE CURRENT INTERNAL REVENUE CODE

Current code sections are available by locating the current editions of the following texts.

a. United States Code, US GPO [KF62 2000 .A2] (also available online at GPO Website)

b. United States Code Annotated, West Publishing Co. [KF62 1927.A3]

c. United States Code Service, Lexis Publishing. [KF62 1972.U5]

d. Standard Federal Tax Reporter, CCH. [KF6365.C58]
The IRC is compiled in volumes 1-18 of the Standard.  The Code is also available within the set's two companion volumes marked Internal Revenue Code I and II. Also available through CCH Tax Research Network. [Subscription Database (GULC only)]

e. Federal Tax Coordinator, RIA.[KF6285 .F4 1984], also available through Checkpoint, RIA [Subscription Database (GULC Only)].

f. United States Tax Reporter, RIA. [KF6280.P7 1992]
Code sections are contained within the set's main compilation volumes.  The Code is also compiled without annotations in a two volume companion set. Also available through Checkpoint, RIA. [Subscription Database (GULC only)]

g. Checkpoint, RIA. [Subscription Database (GULC only)]
Consolidates the full text of primary and secondary materials in the areas of federal, state, and international taxation.

h. CCH Tax Research Network. [Subscription Database (GULC only)]
Consolidates the full text of primary and secondary materials in the areas of federal, state, and international taxation.

LEXIS: Legal > Area of Law - By Topic > Taxation > Statutes & Legislative Materials > Federal > USCS-Title 26;Internal Revenue Code Annotated    Get a Document; 26 usc 280

i. WESTLAW: FTX-USCA    Find; 26 usc 280

2. LOCATING PRIOR YEAR TAX LAWS

The publications listed below provide access to prior versions of amended tax laws.  Also provided within these materials are the texts of repealed legislation.  Earlier tax laws are also available in earlier editions of each of the titles listed immediately above, under the heading "Locating the Current Internal Revenue Code".   To find the code from a particular year, go to that year's edition of any of the above sources.

a. United States Code, US GPO [KF62 2000 .A2]
The library has the US Code from 1925 - the present available on microfiche in Media Services on the 3rd floor of the library.

b. Cumulative Changes in the Tax Regulations under the 1986 Code, RIA.  [KF6285 .P7 1987]
This three volume loose-leaf contains reprints of prior provisions of regulations involving income, estate, and gift tax, penalty excise taxes on public charities, private foundations, retirement wages, withholding on wages and procedure and administration regulations.  This source is useful for tracking changes in the Code, as well as tracking changes for Treasury regulations.

c. Cumulative Changes in Internal Revenue Code of 1954 and Tax Regulations Under the Code, Prentice Hall.  [KF6285 .P7]
Contains reprints of 1954 tax codes and their amendments.  Also reprinted is the full text of regulations and their amendments.

d. Internal Revenue Acts of the United States: 1909 - 1950; 1950 - 1951, United States.  [KF6276 .I57 1979, 1982]   Index available at
[KF6276 .I57 1979 Index]
Compiled in two editions, 1979 and 1982, these sources provide full text reprints of tax laws from 1909 - 1950 and 1950 - 1951.

e. Legislative History of Federal Income Tax Laws 1938 - 1861; 1953 - 1939, Prentice Hall.  [KF6355 .S8 1938, 1954]
1938 edition reprints income tax codes, reports and other documents from 1861 - 1938.  The later 1954 edition provides reprints of tax acts and other documents covering 1939 - 1953.

f. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5]. Also available through Westlaw [Subscription Database (GULC only)]

g. Federal Income, Gift and Estate Taxation, Matthew Bender. [KF6335.A6 R34] . Also available through Lexis.

h. Checkpoint, RIA. [Subscription Database (GULC only).] Archives the tax code to 1990.

i. CCH Tax Research Network. [Subscription Database (GULC only).] Archives the tax code to 1978.

j. LEXIS: Search appropriate year within historical archive dating back to 1992.

k. WESTLAW: Search appropriate year within historical archive dating back to 1990.

3. LOCATING PENDING LEGISLATION

Finding very current or pending tax legislation does not have to be difficult.  There are a number of print and on-line sources available that track the current activities of Congress.  The sources listed below are useful legislative current awareness tools useful when tracking pending legislation.

a. Congressional Index, CCH [KF 49 .C6]
The Congressional Index is a wonderful source for tracking legislation currently under consideration by Congress.  This loose-leaf offers a digest of bills pending in Congress.  As with other CCH products, this source provides extensive indexing allowing the researcher the ability to search by subject, bill author, or bill number.  The Congressional Index also provides citations to reports, hearings, debates and various bill versions, as well as other legislative materials.

b. Standard Federal Tax Reporter, CCH. [KF6365.C58] Also available through CCH Tax Research Network. [Subscription Database (GULC only)]
The "New Developments" volume of the Standard is designed as a current awareness tool for current developments in tax legislation, recent judicial decisions and up-to-date changes from within the Treasury or Internal Revenue Service.  Within this volume there is a tab marked "20xx Legislation" that contains a "Legislative Status Table" listing newly introduced tax bills.  Also presented are descriptions of proposed bill provisions and the latest action taken.

c. CCH Tax Research Network. [Subscription Database (GULC only)]. Select the "Federal" tab, then either "CCH Legislation Newswire" (which links to news stories about recent legislation) or "Bills Worth Watching" (which provides citations to and brief summaries of pending bills).

d. United States Tax Reporter, RIA. [KF6280.P7 1992] Also available through Checkpoint, RIA. [Subscription Database (GULC only)]
The USTR offers a "New Legislation Status Table" finding lists that tracks the progress of newly reported and introduced bills.  Also available, is the "List of Code Sections Proposed for Amendment", which indicates Code sections that would be amended by pending bills.

e. Checkpoint, RIA. [Subscription Database (GULC only)]. Under "Primary Source Materials," expand the heading "Current Pending/Enacted Legislation."

f. Daily Tax Report, Bureau of National Affairs. [KF6289 .A1 D3]
As a newsletter, the Daily Tax Report provides timely tax information.  Newsletters usually offer the text of reports, laws, regulations, decisions and other pronouncements far in advance of traditional print materials. This newsletter is also available electronically through BNA, and on Lexis and Westlaw.

g. Tax Notes Today
Available on LEXIS: Legal > Area of Law - By Topic > Taxation > Legal News > Tax Analysts Tax Notes Today. This database is no longer available in our Westlaw subscription.

h. Tax Management Washington Tax Review, Tax Management, Inc. [KF6297 .B956]

i. Tax Analysts' Daily Tax Highlights & Documents, Tax Analyst's. [KF6272 .T64]

j. THOMAS: Online database maintained by the Library of Congress. Offers the ability to search for bills currently pending before Congress in addition to the ability to search for bills in prior sessions of Congress as well. The database provides bill information from the 101st Session of Congress to the present.

4. CITATION TOOLS FOR STATUTES

a. LEXIS: Shepard's

b. WESTLAW: KeyCite

D. LEGISLATIVE HISTORY

When researching federal tax statutes, the researcher may find it necessary to consider legislative interpretations to either substantiate or undermine an interpretation of a provision.  The process of compiling tax legislative histories is comparable to the method used to assemble legislative documents for other federal laws.  For this reason an understanding of how a bill becomes law and the documents created along each step of the process is required when compiling legislative histories. It is also a good idea to check to see if anyone else has already compiled a legislative history of the act you are researching. Resources that will help you do this are

1. Union List of Legislative Histories, Rothman & Co. [KF4 .U55]

2. Sources of Compiled Legislative Histories, Rothman & Co. [KF42.2 1979].

3. Sources of Compiled Legislative Histories Database (available from HeinOnline -GULC users only)

When compiling legislative materials for tax issues there are three, possibly four committee reports that should be considered, along with pertinent hearings, debates and varying bill versions. Keep in mind that committee reports are the most persuasive documents of legislative history. Therefore, if your time or other research resources are limited and you must research legislative history, you should focus your efforts on obtaining the committee reports.

The progression for federal tax legislation begins in the Ways and Means Committee of the House of Representatives.  Within this committee a subcommittee is formed to draft a proposed bill.  This bill is then presented to the full House for approval.  Once accepted by the House, the bill is sent to the Senate where the Senate Finance Committee considers the piece of legislation and creates its own Senate bill draft.  When discrepancies arise, a Conference Committee made up of both Ways and Means and Senate Finance members, is formed to reconcile any differences between the House and Senate bills.  It is the responsibility of the Conference Committee to reach a compromise between the two bills and to then create a new bill reflective of these modifications.  In addition to the various bill versions, committee reports are generated by each of the three committees.  Each committee report is important when researching legislative intent; however, the Conference report is often most informative, as it illustrates the original purpose and expressed objectives put forth from both the House and Senate during the compromise process.

In addition to the reports created by the House Way and Means, Senate Finance and Conference Committees, a fourth report is sometimes published by the Joint Committee on Taxation (JCT) <http://www.jct.govt>.  The JCT is made up of members from the Ways and Means and Finance Committees, but unlike the other committees, the JCT does not produce legislation.  It is this committee's responsibility, among other things, to conduct studies and to assist the Ways and Means, Finance and Conference Committees in the bill drafting process.  After the enactment of significant tax code provisions, the JCT publishes the General Explanation also known as the "Blue Book."   This resource provides useful explanations of the newly enacted tax acts.  The Blue Book is considered primary authority. However, the JCT does not produce a General Explanation for every tax enactment.

To locate committee reports the easiest methods are by using the Public Law number or relevant code section number.  (For additional tips on how to compile legislative materials consult the library's Legislative History Research Guide available on the web at http://www.ll.georgetown.edu/guides/legislative_history.cfm).

1. LOCATING COMMITTEE REPORTS BY CODE SECTION

a. Tax Management Primary Sources, BNA. Series 1-3 [KF6297 .B9525], Series 4-5 [KF6297 .B9525]
BNA has published a five series loose-leaf that provides legislative history documents from 1969 forward.  Available within the text are excerpts of treasury studies, presidential messages, House and Senate reports, Conference reports, and debates.  Series coverage is as follows:  Series I, 1969 - 1975; Series II, 1976 - 1977; Series III, 1978 - 1980, Series IV, 1981 - 1986; Series V, from 1987 - to date.

b. Rabkin & Johnson, Federal Income, Gift and Estate Taxation, Matthew Bender. [KF6335.A6 R34]; also available online from Lexis
Volumes 6, 6A, 6B, 7, 7A & 7B contain selected committee reports.

c. Seidman's Legislative History of Federal Income Tax Laws, 1938 - 1861. [KF6355 .S8 1938]
Provide excerpts of tax legislation. Seidman's does not cover estate and gift taxes. (Full-text available via HeinOnline to GULC only).

d. Seidman's Legislative History of Federal Income and Excess Profits Tax Laws, 1939 - 1863, Prentice Hall. [KF6355.8 1954] Provides excerpts of tax legislation.  It does not cover estate and gift taxes. (Full-text available via HeinOnline to GULC only).

e. Checkpoint, RIA. [Subscription Database (GULC only)] 104 - current congress

2. LOCATING COMMITTEE REPORTS BY PUBLIC LAW NUMBER

a. Internal Revenue Bulletin, US GPO [KF6301 .A12]; available on IRS website (1996 - present).

b. Internal Revenue Cumulative Bulletin, US GPO[KF6301 .A1]

c. US Code Congressional and Administrative News, West. [Reading Room & 4th Fl. KF48 .U54; also available electronically on Westlaw: USCCAN]
USCCAN provides access to selected legislative documents including bills and House, Senate and Conference committee reports.  This resource also offers citations to debates published in the Congressional Record.

d. Internal Revenue Acts of the United States: 1909 - 1950, Hein. [KF6276 .I57 1979]
Provides full text with original pagination for legislative tax documentation.

e. Internal Revenue Acts of the United States: 1950 - 1951, Hein.  [KF 6276 1982]
Provides full text with original pagination for legislative tax documentation.

f. Internal Revenue Acts of the United States: 1953 - 1972, Hein. [KF6275.8 1985]
Provides full text with original pagination for legislative tax documentation.

g. Internal Revenue Acts of the United States: the Revenue Act of 1954, Hein. [KF6275.8 1982r]
Provides full text with original pagination for legislative tax documentation. (Full-text is available online via HeinOnline to GULC only)

h. CIS, Congressional Information Service. [ KF49 .C619]
Provides citations and brief descriptions of legislative documents.  Also available electronically through Lexis Nexis Congressional (GULC only) and through Lexis. The library has the full microfiche set produced by CIS, so all documents cited in the indexes are available in the library.

i. Lexis Congressional , [Subscription Databases (GULC only)]
Offers access to the full text of public laws, congressional reports, documents, prints, bill text, the Congressional Record, and CIS legislative indexes.

j. Checkpoint, RIA. [Subscription Database (GULC only)] 104th - current Congress

k. Thomas: http://thomas.loc.gov 101st - current Congress

l. LEXIS: Legal > Area of Law - By Topic > Taxation > Statutes & Legislative Materials > Federal > US - CIS Legislative Histories - Federal Tax Law

m. WESTLAW: LH

3. LOCATING HEARINGS

Not all Congressional hearings are published. Published hearings can be located by searching the library's online catalog Gulliver, as the library acquires a significant number of hearings in print and in microform.  Hearings can also be found using the following resources:

a. Tax Management Primary Sources, BNA. Series 1-3 [KF6297 .B9525], Series 4-5 [KF6297 .B9525]

b. Seidman's Legislative History of Federal Income and Tax Laws 1938 - 1861, Prentice Hall. [ KF6355 .S8 1938]; Also available electronically from Hein
Provides excerpts of tax legislation. Seidman's does not cover estate and gift taxes.

c. Seidman's Legislative History of Federal Income and Excess Profits Tax Laws, 1953 - 1939, Prentice Hall. [KF6355.8 1954]; Also available electronically from Hein
Provide excerpts of tax legislation. Seidman's does not cover estate and gift taxes.

d. Internal Revenue Acts of the United States: 1909 - 1950, Hein. [KF6276 .I57 1979]

e. Internal Revenue Acts of the United States: 1950 - 1951, Hein.  [KF 6276 1982]

f. Internal Revenue Acts of the United States: 1953 - 1972, Hein. [KF6275.8 1985]
Provides full text with original pagination for legislative tax documentation.

g. Internal Revenue Acts of the United States: the Revenue Act of 1954, Hein. [KF6275.8 1982r]

h. CIS, Congressional Information Service. [KF49 .C619] (1970 - )
Provides citations and brief descriptions of legislative documents.  Also available electronically through LexisNexis Congressional (GULC only) and through Lexis. The library has the full microfiche set produced by CIS, so all documents cited in the indexes are available in the library.

i. Lexis Congressional , [Subscription Databases, (GULC only)] (1970 - )
Offers access to the full text of public laws, congressional reports, documents, prints, bill text, the Congressional Record, and CIS legislative indexes.

j. LEXIS: Legal > Legislation & Politics - U.S. & U.K. > U.S. Congress > Committee Hearing Transcripts

k. WESTLAW: USTESTIMONY

l. FDSYS - GPO Access (104th Congress-)

m. House Ways and Means Committee - http://waysandmeans.house.gov/

n. Senate Finance Committee- http://www.senate.gov/~finance/

4. LOCATING DEBATES AND FLOOR STATEMENTS

a. Congressional Record, US GPO [KF35 .A26] (full text)

b. Lexis Congressional [Subscription Databases (GULC only)]
Offers access to the full text of public laws, congressional reports, documents, prints, bill text, the Congressional Record (1985 - ), and CIS legislative indexes.

c. CIS, Congressional Information Service. [KF49 .C619]
Provides citations and brief descriptions of legislative documents, including floor debates.  Also available electronically through LexisNexis Congressional (GULC only) and through Lexis. The library has the full microfiche set produced by CIS, so all documents cited in the indexes are available in the library.

d. US Code Congressional and Administrative News, West's. [KF48 .U54]
This resource provides citations to debates published in the Congressional Record.

e. Tax Management Primary Sources, BNA. Series 1-3 [KF6297 .B9525], Series 4-5 [KF6297 .B9525]
Provides debate excerpts.

f. Internal Revenue Acts of the United States: 1909 - 1950, Hein. [KF6276 .I57 1979]
Provides full text with original pagination for legislative tax documentation.  Text and Legislative History.

g. Internal Revenue Acts of the United States: 1950 - 1951, Hein.  [KF 6276 1982]
Provides full text with original pagination for legislative tax documentation.  Text and Legislative History.

h. Internal Revenue Acts of the United States: 1953 - 1972, Hein. [KF6275.8 1985]
Provides full text with original pagination for legislative tax documentation.  Text and Legislative History.

i. Seidman's Legislative History of Federal Income and Tax Laws 1938-1861, Prentice Hall. [KF6355 .S8 1938]; Also available electronically from Hein
Provide excerpts of tax legislation. Seidman's does not cover estate and gift taxes.

j Seidman's Legislative History of Federal Income and Excess Profits Tax Laws, 1953 - 1939, Prentice Hall. [KF6355.8 1954]; Also available electronically from Hein.
Provide excerpts of tax legislation. Seidman's does not cover estate and gift taxes.

k. LEXIS: Legal > Area of Law - By Topic > Taxation > Statutes & Legislative Materials > Federal > Congressional Record (1985 - )

l. WESTLAW: FTX-CR (1985 - )

m. Thomas: (1989 - )

n. FDSYS: Daily Congressional Record (1994 - )

5. LEGISLATIVE HISTORY INDEXES

a. Union List of Legislative Histories, Rothman & Co. [KF4 .U55].

b. Sources of Compiled Legislative Histories, Rothman & Co. [KF42.2 2005 ]. Also available online from Hein.

c. A Guide and Analytical Index to the Internal Revenue Acts of the United States, 1909 - 1950: Legislative Histories, Laws and Administrative Documents. [KF6276 .I57 1979 Index]

d. Bulletin Index - Digest System [KF6301 .A2]
This source provides a sequential index for all tax related public laws from 1953 - 1993. Included within the listing are Cumulative Bulletin citations to public laws and their related committee reports.

e. CIS, Congressional Information Service. [KF49 .C619]
Provides citations and brief description of legislative documents.  Also available electronically through LexisNexis Congressional (GULC only) and through Lexis (Legal > Area of Law - By Topic > Taxation > Statutes & Legislative Materials > Federal > US - CIS Legislative Histories - Federal Tax Law). The library has the full microfiche set produced by CIS, so all documents cited in the indexes are available in the library.

ADMINISTRATIVE SOURCES

The Treasury Department has statutory authority to interpret and administer the Internal Revenue Code.  The Internal Revenue Service, a division of the Treasury Department, is charged with the day-to-day operations associated with the provisions of the Internal Revenue Code.  As for administrative authority, there are four major pronouncements promulgated by the IRS and Treasury Department.  These four pronouncements are regulations, revenue rulings, revenue procedures and letter rulings.

A.  REGULATIONS (C.F.R Title 26 )

Regulations are laws made by an executive branch agency like the Treasury Department under the authority of a statute passed by Congress. The statutes that give the Treasury Department its authority to make regulations are found in the Internal Revenue Code.  The Treasury Department issues three types of administrative regulations: proposed, temporary and final.  Before a regulation is finalized, it must first be published as a proposed regulation (aka notice of proposed rulemaking). During this period, interested parties are allowed to comment on the proposed regulation, either by submitting written comments or by testifying. The Treasury Department considers these comments and, if found necessary, changes are made.  After this comment period, the regulations are finalized and published in the form of final regulations.  On rare occasions, the Treasury Department will issue an advanced notice of proposed rulemaking. An Advanced Notice notifies the general public that the Treasury Department is considering issuing regulations for a particular tax issue, and it invites interested parties to submit commentary on the Treasury's proposal to issue new regulations.

Temporary regulations are issued to provide guidance to tax payers on new tax provisions. Temporary regulations do not require a public comment period and are effective immediately after publication. Final and Temporary regulations are first published as Treasury Decisions (TD).  Treasury Decisions are recognized by a four digit citation, i.e. T.D. 8860 and include a preamble statement describing the purpose and content of the new regulation. Once codified, regulations are assigned a prefix number that coincides with its corresponding tax code section, as indicated in the illustration below.   (ex. 1.262-3,  The number 1 before the decimal indicates that this is an income tax provision, 262 represents the related code section number.  The number 3 after the dash is the regulation number). The illustration below displays commonly encountered regulations and their corresponding code section citations.

1. LOCATING TREASURY DECISIONS, FINAL & TEMPORARY REGULATIONS

a. Federal Register, US GPO [KF70 .A2; available electronically on the FDSYS home page (1994 - )]. Print copies are replaced by microfiche.

b. Internal Revenue Bulletin, US GPO [KF6301 .A12; available electronically on the IRS home page (1996 - present)]

c. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1; available electronically from LLMC Digital and Hein (GULC only)]

d. Code of Federal Regulations, US GPO [KF70 .A3; available electronically on the GPO Access home page]. Tax regulations are located in Title 26 of the C.F.R.

e. Standard Federal Tax Reporter, CCH. [KF6365.C58]; Also available electronically through the CCH Tax Research Network. [Subscription Database (GULC only)]

f. United States Tax Reporter, RIA. [KF6280.P7 1992]
Also available electronically through Checkpoint, RIA. [Subscription Database (GULC only)]

g. Federal Tax Coordinator 2d, RIA. [KF6285.F4] Also available through Checkpoint, RIA [Subscription Database (GULC only)]
Also available electronically through Checkpoint, RIA. [Subscription Database (GULC only)]

h. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5]; Also available electronically through Westlaw [Subscription Database (GULC only)]

i. Federal Tax Regulations, West's. [KF6276.99 .W4]
Updated by United States Code Congressional and Administrative News (USCCAN).

j. Daily Tax Report, BNA. [KF6289.A1 D3; also available on BNA (GULC only)]

k. Tax Analysts' Daily Tax Highlights & Documents, Tax Analyst's. [KF6272 .T64]

l. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > CFR - Federal Tax Regulations;    Get a Document: 26 cfr 1.151-1

m. WESTLAW: FTX-TD;    Find: 26 cfr 1.151-1

n. Checkpoint RIA. [Subscription Database (GULC only)]
Consolidates the full text of primary and secondary materials in the areas of federal, state, and international taxation.

o. CCH Tax Research Network. [Subscription Database (GULC only)]
Consolidates the full text of primary and secondary materials in the areas of federal, state, and international taxation.

2. LOCATING PROPOSED REGULATIONS (Prop. Reg.)

Unlike final and temporary regulations, proposed regulations have not been assigned a corresponding code section number.  Most services offer a code section cross reference table that gives reference to the assigned code section.

a. Federal Register, US GPO [KF70 .A2; available electronically on the FDSYS home page (1994 - )]. Print copies are replaced by microfiche.

b. Internal Revenue Bulletin, US GPO [KF6301 .A12]; available electronically on the IRS home page (from 1996 - present)

c. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1;available electronically from LLMC Digital and Hein (GULC only)]

d. Standard Federal Tax Reporter, CCH. [KF6365.C58]; Also available electronically through the CCH Tax Research Network. [Subscription Database (GULC only)]
See United States Tax Cases Advanced Sheets volume and the Cumulative Index in the New Matters vol.

e. United States Tax Reporter, RIA. [KF6280.P7 1992]
See vol. 18 for Proposed regs. Also available electronically through Checkpoint, RIA. [Subscription Database (GULC only)]

f. Federal Tax Coordinator 2d, RIA. [KF6285.F4] Also available through Checkpoint, RIA [Subscription Database (GULC only)]
See vol. 27 proposed regs. Also available electronically through Checkpoint, RIA. [Subscription Database (GULC only)]

g. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5]; Also available electronically through Westlaw [Subscription Database (GULC only)]

h. Daily Tax Report, BNA. [ KF6289.A1 D3] Also available electronically through BNA Publications [Subscription Database (GULC only)]

i. Tax Analysts' Daily Tax Highlights & Documents, Tax Analyst's. [KF6272 .T64]

j. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Treasury Regulations - Proposed

k. WESTLAW: FTX-PR

l.Checkpoint, RIA.[Subscription Database (GULC only)]
Consolidates the full text of primary and secondary materials in the areas of federal, state, and international taxation.

m. CCH Tax Research Network. [Subscription Database (GULC only)]
Consolidates the full text of primary and secondary materials in the areas of federal, state, and international taxation.

3. LOCATING PENDING REGULATIONS

a. Federal Register, US GPO [KF70 .A2; available electronically on the FDSYS home page]. In April and October, the Federal Register publishes the IRS Semiannual Agenda of Regulations.  This resource reports on the status of pending regulations during the coming six month time period.

b. Daily Tax Report, BNA. [KF6289.A1 D3]
Monthly, the Daily Tax Report publishes the IRS on Regulations Projects Status and Disposition Report identifying pending regulations. Also available electronically through BNA Publications.

c. Standard Federal Tax Reporter, CCH. [KF6365.C58]; Also available electronically through the CCH Tax Research Network. [Subscription Database (GULC only)]
See United States Tax Cases volume & Cumulative Index in the New Matters vol.  Status table.

d. United States Tax Reporter, RIA. [KF6280.P7 1992] Also available electronically through Checkpoint, RIA. [Subscription Database (GULC only)]
For print source see vol. 16 "New Legislation".

e. Tax Notes, Tax Analyst's and Advocates. [KF6272 .T3]
Tax Notes publishes the Treasury/IRS Annual Business Plan that  identifies regulations from upcoming projects.

4. LOCATING REGULATIONS FROM PRIOR YEARS

To find earlier regulations, locate prior editions of the following sources.  Electronic databases offer archived regulations going back to the 80's.

a. Federal Register, US GPO [KF70 .A2; available electronically on the FDSYS home page (1994 - )]. Print copies are replaced by microfiche (3rd Fl Media).

b. Internal Revenue Bulletin, US GPO [KF6301 .A12; available electronically on the IRS home page (1996 - present)]

c. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1;available electronically from LLMC Digital and Hein (GULC only)]

d. Code of Federal Regulations, US GPO [KF70 .A3; available electronically on the GPO Access home page]. Tax regulations are located in Title 26 of the C.F.R.

e. Standard Federal Tax Reporter, CCH. [KF6365.C58]; Also available electronically through the CCH Tax Research Network. [Subscription Database (GULC only)]

f. United States Tax Reporter, RIA. [KF6280.P7 1992]
Also available electronically through Checkpoint, RIA. [Subscription Database (GULC only)]

g. Federal Tax Regulations, West's. [KF6276.99 .W4]
Updated by United States Code Congressional and Administrative News (USCCAN).

h. Federal Tax Coordinator 2d, RIA. [KF6285.F4] Also available electronically through Checkpoint, RIA. [Subscription Database (GULC only)]

i. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5]; Also available electronically through Westlaw [Subscription Database (GULC only)].

j. Daily Tax Report, BNA. [KF6289.A1 D3]. Also available electronically through BNA Publications [Subscription Database (GULC only)].

k. LEXIS: Search archived regulations file.

l. WESTLAW: Search archived regulations database.

m. Checkpoint, RIA. [Subscription Database (GULC only)]

n. CCH Tax Research Network. [Subscription Database (GULC only)]

5.  LOCATING PREAMBLES

Preambles accompany newly released regulations and offer insight into the intent and purpose behind the regulation.  Preambles describe in laymen's terms the basis and content of the new regulation.  In addition, they often reveal the nature of the comments received during the comment period and accommodations made to reconcile the regulation.

a. Federal Register, US GPO [KF70 .A2; available electronically on the FDSYS home page]. Print copies are replaced by microfiche (3rd Fl Media).

b. Internal Revenue Bulletin, US GPO [KF6301 .A12; available electronically on the IRS home page (1996 - present)]

c. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1;available electronically from LLMC Digital and Hein (GULC only)]

d. Standard Federal Tax Reporter, CCH. [KF6365.C58]; also available electronically from CCH Tax Research Network (GULC only).
See New Matters volume, "Treasury Decision Preambles" tab.

e.United States Tax Reporter, RIA. [KF6280.P7 1992] Also available through Checkpoint, RIA. [Subscription Database (GULC only)]
See vol.18 Proposed Regulations - Preambles.

f. Daily Tax Report, BNA. [KF6289.A1 D3]; Also available electronically through BNA Publications [Subscription Database (GULC only)].

g. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5] Also available on Westlaw [Subscription Database (GULC only)]

h. Checkpoint RIA. [Subscription Database (GULC only)]

i. CCH Tax Research Network. [Subscription Database (GULC only)]
 

6.  UPDATING REGULATIONS

a. Checkpoint, RIA. [Subscription Database (GULC only)]. Click "Citator 2d."

b. CCH Tax Research Network. [Subscription Database (GULC only)]. Click the "Check Citator" button.

c. LEXIS: Shepard's

d. WESTLAW: KeyCite

B.  REVENUE RULINGS (Rev. Rul.)

Revenue Rulings are official declarations made by the IRS stating its view of how the tax law applies to a specific set of facts. These rulings have precedential value for taxpayers with analogous fact patterns to the facts presented in the revenue ruling.  Prior to the 1954 tax code, Revenue Rulings were also known by different names .  These early names include Appeals and Review Memorandum (ARM), General Counsel's Memorandum (GCM) and Office Decisions (OD).

1. LOCATING REVENUE RULINGS

a. Internal Revenue Bulletin, US GPO [KF6301 .A12; available electronically on the IRS home page (1996 - present)]

b. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1;available electronically from LLMC Digital and Hein (GULC only)]

c. Standard Federal Tax Reporter, CCH. [KF6365.C58]; available electronically from CCH Tax Research Network (GULC only)

d. United States Tax Reporter, RIA. [KF6280.P7 1992] Also available through Checkpoint, RIA. [Subscription Database (GULC only)]

e. Federal Tax Coordinator 2d, RIA. [KF6285.F4] Also available through Checkpoint, RIA [Subscription Database (GULC Only)]

f. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5] Also available through Westlaw [Subscription Database (GULC only)]

g. Daily Tax Report, BNA. [KF6289.A1 D3] Available electronically though BNA [Subscription Database (GULC only)]

h. Tax Analysts' Highlights and Documents, Tax Analyst's. [KF6272 .T64]

i. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Cumulative Bulletin and Internal Revenue Bulletin;   
Get a Document: rev rul 85-167 (pre 2000 format), rev rul 2000-1 (post 2000 format)

j. WESTLAW: FTX-RR    Find: rev rul 85-167

k. Checkpoint RIA. [Subscription Database (GULC only)]

l. CCH Tax Research Network. [Subscription Database (GULC only)]

C.  REVENUE PROCEDURES (Rev. Proc.)

Revenue Procedures are statements made by the IRS concerning inside IRS practices and procedures that may or may not affect the rights or duties of taxpayers under the Internal Revenue Code. Revenue Procedures are also issued to disseminate information that should be a matter of public knowledge.

1.  LOCATING REVENUE PROCEDURES

a. Internal Revenue Bulletin, US GPO [KF6301 .A12; available electronically on the IRS home page (1996-present)]

b. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1;available electronically from LLMC Digital and Hein (GULC only)]

c. Standard Federal Tax Reporter , CCH. [KF6365.C58]; available electronically from CCH Tax Research Network (GULC only)

d. United States Tax Reporter, RIA. [KF6280.P7 1992] Also available through Checkpoint, RIA. [Subscription Database (GULC only)]

e. Federal Tax Coordinator 2d, RIA. [KF6289.A1 D3] Also available through Checkpoint, RIA [Subscription Database (GULC only)]

f. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5] Also available through Westlaw [Subscription Database (GULC only)]

g. Daily Tax Report, BNA. [KF6289.A1 D3] Also available electronically through BNA [Subscription Database (GULC only)]

h. Tax Analysts' Highlights and Documents, Tax Analyst's. [KF6272 .T64]

i. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Cumulative Bulletin and Internal Revenue Bulletin;   
Get a Document: rev proc 85-167 (pre 2000 format), rev proc 2000-1 (post 2000 format)

j. WESTLAW: FTX-RP    Find:  rev proc 86-22

k. Checkpoint RIA. [Subscription Database (GULC only)]

l. CCH Tax Research Network. [Subscription Database (GULC only)]

D.  LETTER RULINGS (Private Letter Rulings, P.L.R., Priv. Ltr. Rul., L.R., Ltr. Rul.)

A Letter Ruling is a written statement issued to a taxpayer by the IRS National Office that interprets and applies the tax laws to the taxpayer's specific set of proposed facts. Letter Rulings are similar to Revenue Rulings, but they are relied upon as precedent only by the taxpayer to whom the ruling is issued. They are sometimes referred to as Private Letter Rulings because the names of tax payers are expunged.

1. LOCATING LETTER RULINGS

a. IRS Letter Rulings, CCH. [KF6282.A2 C65] (1977- to date)
Contains the full text of Private Letter Rulings, Technical Advice Memoranda.

b. IRS Positions Reporter, CCH. [KF6301.A6 I78] (1982-to date)
Official Internal Revenue Service General Counsel's Memoranda, Technical Memoranda, Actions on Decisions.

c. Internal Memoranda of the IRS, Prentice Hall. [KF6301.A6 P7] (1982-1990)

d. IRS Memoranda & Letter Rulings, Maxwell Macmillian. [KF6301.A6 .P7 1990] (1990-1991)

e. IRS Technical Advice Memorandums and IRS Letter Rulings, Tax Analyst's. [KF6301.A15 I73] (1986-1998)

f. Daily Tax Report, BNA. [KF6289.A1 D3] Also available electronically through BNA [Subscription Database (GULC only)]

g. Letter Ruling Summaries & Citations, Tax Analyst's. [KF6301.A33 T39]

h. Tax Analysts' Daily Tax Highlights and Documents,  Tax Analyst's. [KF6272 .T64]

i. Checkpoint, RIA. [Subscription Database (GULC only)]

j. CCH Tax Research Network. [Subscription Database (GULC only)]

k. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Private Letter Rulings and Technical Advice Memoranda;   
Get a Document: plr 199905024

l. WESTLAW: FTX-PLR    Find: plr 199905024
 

E. ACTIONS ON DECISIONS AND IRS ACQUIESCENCE

AOD's are statements made by the IRS clarifying its decision to either appeal or not appeal an adverse case.  AOD's reveal whether the IRS plans to acquiesce (acq) or nonacquiesce (non acq) in future litigation where the issue arises again. An acquiescence indicates that the IRS intends to follow the decision of the court in similar situations. In some instances the Government will acquiesce to the result of the court's decision but not the court's reasoning (described as an acquiescence to the result only). A nonacquiescence indicates that the IRS disagrees with the ruling of the court and will not extend acceptance of this ruling to other taxpayers.

1. LOCATING ACTIONS ON DECISIONS

a. IRS Positions Reporter, CCH. [KF6301.A6 I78]
Official Internal Revenue Service General Counsel's Memoranda, Technical Memoranda, Actions on Decisions.

b. IRS Administrative Documents, Tax Analyst's. [KF6301.A15 I72] (1987-1991).
Includes General Counsel Memorandums, Technical Memorandums regarding regulations, and Actions on Decisions.

c. Tax-related Administrative Documents, Tax Analyst's. [KF6301.A15 I72] (1991-1992).
Includes General Counsel Memorandums, Technical Memorandums regarding regulations, and Actions on decisions.

d. Tax Notes, Tax Analyst's. [KF6272 .T3]

d. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Actions on Decisions;   
Get a Document: aod 1997-004

e. WESTLAW: FTX-AOD   Find: aod 1997-004

f. Checkpoint, RIA. [Subscription Database (GULC only)]

g. CCH Tax Research Network. [Subscription Database (GULC only)]

h. IRS Website: provides selected Actions on Decisions from 1997 - present.

F. ANNOUNCEMENTS (Ann.)

Public IRS pronouncements written by the office of the Chief Counsel announcing information of general importance.  Announcements have only immediate or short-term value.

1. LOCATING ANNOUNCEMENTS

a. Internal Revenue Bulletin, US GPO [KF6301 .A12]; available electronically on IRS homepage (1996 - present)

b. Standard Federal Tax Reporter, CCH. [KF6365.C58]; available electronically from CCH Tax Research Network (GULC Only)
To locate announcements, use the Finding List in the Citator volume.

c. Checkpoint, RIA. [Subscription Database (GULC only)]

d. CCH Tax Research Network. [Subscription Database (GULC only)]

e. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Advance Releases;    
Get a Document: announcement 2000-32 (post 2000 format),  (pre 2000) announcement 99-144.

f. WESTLAW: FTX-ANN    Find: announcement 2000-32 (post 2000 format),  (pre 2000) announcement 99-144.

G. FIELD SERVICE ADVICE (F.S.A.)

Field Service Advice memos emanate from the IRS national office. These memos provide nonbinding advice and guidance to IRS agents, attorneys and appeals officers to help them develop issues or determine litigation hazards for both substantive and procedural matters. They cannot be cited as precedent. FSA's can be either formally written or informally handwritten summaries of telephone inquiries. Field Service Advice may be requested without the taxpayers knowledge.

1. LOCATING FIELD SERVICE ADVICE MEMORANDUMS

a. Full Text IRS Technical Advice Memorandums, Field Service Advice Memos, Letter Rulings, Service Center Advice, and Other Forms of  Chief Counsel Advice, Tax Analyst's. [KF6301.A15 I74] (Current two years only).

b. IRS Technical Advice Memorandums and IRS Letter Rulings, Tax Analyst's. [KF6301.A15 I73] (1986-1998)

c. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Field Service Advice Memorandums;   
Get a Document: irs fsa 200015024

d. WESTLAW: FTX-FSA    Find: IRS fsa 200015024

e. Checkpoint, RIA. [Subscription Database (GULC only)]

f. CCH Tax Research Network. [Subscription Database (GULC only)]

g.IRS Website: Selected Field Service Advice from 2003 - present.
 

H.  GENERAL COUNSEL MEMORANDA (GCM)

GCM's are declarations made by the Chief Counsel that explain reasoning used for revenue rulings, private letter rulings and technical advice memoranda.  Although GCM's hold no precedential authority, they can be used as guides to understand the intent behind IRS positions.

1. LOCATING GENERAL COUNSEL MEMORANDA

a. IRS Positions Reporter, CCH. [KF6301.A6 I78]
Provides official Internal Revenue Service General Counsel's Memoranda, Technical Memoranda, Actions on Decisions.

b. IRS Administrative Documents, Tax Analyst's. [KF6301.A15 I72] (1987-1991).
Includes General Counsel Memorandums, Technical Memorandums regarding regulations, and Actions on Decisions.

c. Tax-related Administrative Documents, Tax Analyst's. [KF6301.A15 I72] (1991-1992).
Includes General Counsel Memorandums, Technical Memorandums regarding regulations, and Actions on decisions.

d. Tax-related Documents, Tax Analyst's. [KF6301.A15 I72] (1992-1993)

e. Tax Analysts' Daily Highlights and Documents, Tax Analyst's. [KF6272 .T64]

f. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS General Counsel Memoranda;   
Get a Document: gcm 39883

g. WESTLAW: FTX-GCM or TNT    Find: gcm 39883

h. Checkpoint, RIA. [Subscription Database (GULC only)]

i. CCH Tax Research Network. [Subscription Database (GULC only)]

j. IRS website: Selected general counsel memoranda available.
 

I. NOTICES

Public IRS pronouncements written by the office of the Chief Counsel announcing new provisions of tax law that may affect taxpayers.

1. LOCATING NOTICES

a. IRS Website: Chief Counsel Notices and Chief Counsel Directives Manual

b. Internal Revenue Bulletin, US GPO [KF6301 .A12]; available electronically on IRS homepage (1996 - present)

c. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1]

d. Standard Federal Tax Reporter, CCH. [KF6365.C58]; available electronically from CCH Tax Research Network (GULC only)
To locate announcements, use the Finding List in the Citator volume.

e. Checkpoint, RIA. [Subscription Database (GULC only)]

f. CCH Tax Research Network. [Subscription Database (GULC only)]

g. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Cumulative Bulletin and Internal Revenue Bulletin   
Get a Document: notice 2000-22 (for post 2000 notices), notice 99-60 (for pre 2000).

h. WESTLAW: FTX-ANN    Find: notice 2000-22 (for post 2000 notices), notice 99-60 (for pre 2000).

J. TECHNICAL ADVICE MEMORANDA (T.A.M., Tech. Adv. Mem., T.A. Memo.)

A Technical Advice Memorandum (TAM) is written guidance provided by the national office of the IRS upon the request of an IRS District Director or an IRS Area Director of Appeals. A TAM responds to a technical or procedural question that develops during the examination of a taxpayer's return, the consideration of a taxpayer's claim for refund, or any other matter that involves the jurisdiction of a District Director or Area Director of Appeals. A TAM only addresses issues that are covered by previously published authority, such as the IRS, a Treasury regulation, tax treaty, revenue ruling, or other precedent. These statements are similar to Letter Rulings, however they are in response to completed tax payer transactions and hold no precedential authority for tax payers other than the intended taxpayer.

1. LOCATING TECHNICAL ADVICE MEMORANDA

a. IRS Technical Advice Memorandums and IRS Letter Rulings, Tax Analyst's. [KF6301.A15 I73] (1986-1998)

b. IRS Administrative Documents, Tax Analyst's. [KF6301.A15 I72] (1987-1991).
Includes General Counsel memorandums, technical memorandums regarding regulations, and actions on Decisions.

c. Tax-related Administrative Documents, Tax Analyst's. [KF6301.A15 I72] (1991-1992).
Includes General Counsel memorandums, Technical memorandums regarding regulations, and Actions on decisions.

d. Tax-related Documents, Tax Analyst's. [KF6301.A15 I72] (1992-1993)

e. IRS Letter Rulings, CCH. [KF6282.A2 C65]. (1977-)
Contains the full text of Private Letter Rulings, Technical Advice Memoranda.

f. Field Service Advice Memos, Letter Rulings, Service Center Advice, and Other Forms of Chief Counsel Advice, Tax Analysts. [KF6301.A15 I74] (Current two years only).

g. Checkpoint, RIA. [Subscription Database (GULC only)]

h. CCH Tax Research Network. [Subscription Database (GULC only)]

i. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Private Letter Rulings and Technical Advice Memoranda    
Get a Document: tam 199934002

k. WESTLAW: FTX-TAM    Find: tam 19993400

K. TECHNICAL MEMORANDA (T.M., Tech. Mem.)

Prepared by the IRS Chief Counsel's office, T.M.'s provide background information on newly released regulations.  Like preambles, TMs reveal the agency's intent and purpose behind the regulation.

1. LOCATING TECHNICAL MEMORANDA

a. IRS Positions Reporter, CCH. [KF6301.A6 I78]
Official Internal Revenue Service General Counsel's memoranda, Technical memoranda, Actions on decisions.

b. Tax Notes, Tax Analyst's and Advocates. [KF6272 .T3]

c. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Decisions > IRS Technical Memoranda

d. WESTLAW: FTX-TM

e. Checkpoint, RIA. [Subscription Database (GULC only)]

f. CCH Tax Research Network. [Subscription Database (GULC only)]
 

L. UPDATING IRS PRONOUNCEMENTS

1. Checkpoint, RIA. [Subscription Database (GULC only)]. Click "Citator 2d."

2. CCH Tax Research Network. [Subscription Database (GULC only)]. Click the "Check Citator" button.

3. United States Tax Reporter - Citator Volumes, available through Checkpoint, RIA. [Subscription Database (GULC only)]

4. Merten's Law of Federal Income Taxation, Callaghan. [KF6365.M5] Also available through Westlaw [Subscription Database (GULC only)]

5. Bulletin Index-Digest System, US GPO [KF6301 .A2]
The Bulletin's section on Actions on Previously Published Revenue Rulings and Procedures list all revenue rulings and revenue procedures that have been affected by later published rulings or procedures. Indications specify treatment of the original item and their Cumulative Bulletin citation.

* Note: There are no published citators for private letter rulings, as they cannot be cited as precedent.
* Note: To locate IRS pronouncements not listed within this guide, see Georgetown's Tax Reference Chart available on the web.

JUDICIAL SOURCES

There are five federal courts that have jurisdiction over disputes between taxpayers and the Government.  All tax cases are first tried in one of three lower level trial courts: the United States Tax Court, the United States District Court, or the United States Court of Federal Claims.  Tax cases tried in all of these courts are later appealed to the United States Courts of Appeals.  Although it is a national court, the Tax Court hears cases in different locations around the country, and appeals of Tax Court cases are heard by the U.S. Court of Appeals for the Circuit in which the taxpayer resides. Appeals of cases from District Courts are heard by the U.S. Court of Appeals for the Circuit in which they sit. Appeals from cases decided by the U.S. Court of Federal Claims are heard by the U.S. Court of Appeals for the Federal Circuit. In tax cases as with all federal cases, the court of last resort is the United States Supreme Court.  Listed below, are marked distinctions and attributes describing each court.

A. UNITED STATES TAX COURT (1942 -  )

The U.S. Tax Court is a specialized court that hears only federal tax cases at the trial level.  Because Tax Court judges are specialists in the area of tax, this court is perceived as being the best court for trying more technical tax issues.  In addition, there is an ostensible advantage for taxpayers who chose to have their cases heard before this court.  Although jury trials are not offered, taxpayers appearing before the Tax Court are not required to pay the disputed tax amount before the case is heard. However, if unsuccessful, the taxpayer will owe interest on the tax liability in dispute.  Before 1943 the U.S. Tax Court was called the Board of Tax Appeals (BTA).

The Tax Court issues two types of decisions, regular and memorandum.  Regular decisions are those decisions involving a new or unusual points of law.  Memorandum decisions deal with established legal issues and interpretations of fact.

1. LOCATING REGULAR TAX COURT DECISIONS

a. Tax Court of the United States Reports. US GPO [KF6280.A2 T35] (1942-1969)
Official reporter. (Cited as T.C.) Continued by Reports of the United States Tax Court.

b. Reports of the United States Tax Court, US GPO [KF6280.A2 T35] (1970 - )
Official reporter. (Cited as T.C.)

c. Tax Court Reporter, CCH. [KF6280 .C58 1965]
Reprints both regular and memorandum decisions.

d. Tax Court Reported and Memorandum Decisions, RIA. [KF6324 .A51]

e. LEXIS: Legal > Area of Law - By Topic > Taxation > Cases and Court Rules > Federal > US Tax Court Cases

f. WESTLAW: FTX-TCT

g. Checkpoint, RIA. [Subscription Database (GULC only)]

h. CCH Tax Research Network. [Subscription Database (GULC only)]

g. U.S. Tax Court Website: has searchable database of opinions from 09/25/95 - present.

2. LOCATING TAX COURT MEMORANDUM DECISIONS

There is no official reporter for memorandum decisions.

a. Tax Court Reporter, CCH. [KF6280 .C58 1965] (1947-)
Reprints both regular and memorandum decisions.

b. Tax Court Reported and Memorandum Decisions, RIA. [KF6324 .A51]
Reprints both regular and memorandum decisions. (Cited as T.C. Memo.)

c. TC Memorandum Decisions, RIA. [KF6324 .A513] (1943-1959,1976- )
Formerly printed by Prentice-Hall. (Cited as RIA TC Memo)

d. Tax Court Memorandum Decisions, CCH. [KF6324 .A515] (1942 - )
(Cited As T.C.M.)

e. LEXIS: Legal > Area of Law - By Topic > Taxation > Cases and Court Rules > Federal > US Tax Court Memorandum Decisions

f. WESTLAW: FTX-TCT

g. Checkpoint, RIA. [Subscription Database (GULC only)]

h. CCH Tax Research Network. [Subscription Database (GULC only)]

i. U.S. Tax Court Website: has searchable database of opinions from 09/25/95 - present.

3. LOCATING BOARD OF TAX APPEALS DECISIONS (1924 - 1942)

a. Reports of the United States Board of Tax Appeals, US GPO [KF6280.A2 T3 ] (1926 - 1942)
Official reporter for regular decisions. (Cited as BTA)

b. BTA-TC Memorandum Decisions,  Prentice-Hall. [KF6324 .A51]
Contains the full text of all memorandum decisions of the Board of Tax Appeals and the Tax Court of the United States rendered 1928 - 1959. US Board of Tax Appeals did not issue Board of Tax Appeals Memorandum Decisions prior to 1928. (Cited as BTA-Memo).

c. LEXIS: Legal > Area of Law - By Topic > Taxation > Cases and Court Rules > Federal > US Board of Tax Appeals Cases

d. WESTLAW: FTX-TCT

e. Checkpoint, RIA. [Subscription Database (GULC only)]

f. CCH Tax Research Network. [Subscription Database (GULC only)]

B. UNITED STATES DISTRICT COURTS

United States District Courts hear all disputes governed by the United States Code, including tax issues.  However, unlike with the Tax Court, taxpayers who bring their cases before the District Court are permitted to request a jury trial.  Taxpayers wishing to dispute the amount of tax in an action brought in a District Court must bring the action as a refund suit, and accourdingly must pay the disputed tax amount before their case is heard.

1. LOCATING DISTRICT COURT TAX DECISIONS

a. Federal Supplement, West's. [KF105 .F44] (1932 - )
(Abbreviated as F. Supp.).

b. Federal Reporter, West's. [KF105 .F4] (1882 - 1932)
(Abbreviated as F., F.2d, F.3d).

c. United States Tax Cases, CCH. [KF6280.A2 C58] (1915- )
For recent decisions, USTC advance sheets can be found in the CCH, Standard Federal Tax Reporter. (Abbreviated as USTC).

d.   American Federal Tax Reports, RIA. [KF6280 .A2] (1924 - )
Contains federal and state court tax decisions. (Abbreviated as AFTR, AFTR 2d). Also available on Checkpoint, RIA. [Subscription Database (GULC only)]

e. LEXIS: Legal > Area of Law - By Topic > Taxation > Cases and Court Rules > Federal > US District Court Tax Cases

f. WESTLAW: FTX-CS

g. Checkpoint, RIA. [Subscription Database (GULC only)]

h. CCH Tax Research Network. [Subscription Database (GULC only)]  

C.   UNITED STATES COURT OF FEDERAL CLAIMS

The Court of Federal Claims hears cases involving monetary claims against the federal government.  As with the District Court, here the taxpayer is also expected to pay their disputed tax debt before the case goes to trial.  There is no right to a jury trial in the Court of Federal Claims for tax cases. Because Federal Claims judges decide on cases involving all aspects of the federal code in addition to tax issues, these judges are not specialist in tax matters.  The Federal Claims Court cases are bound by the decisions made by the Federal District.  Federal Claims trials appeal to the United States Court of Appeals for the Federal District, as it is a national court. Between 1982 and 1992, this court was called the United States Claims Court. Prior to 1982 this court was called the United States Court of Claims.

1. LOCATING UNITED STATES COURT OF FEDERAL CLAIMS TAX DECISIONS

a. Federal Reporter, West's. [KF105 .F4] (1929-1932; 1960 - 1982)
Tax cases are with the 2d and 3d series. (Abbreviated as F.2d, F.3d).

b. Federal Supplement, West's. [KF105 .F44] (1932-1960)
(Abbreviated as F. Supp., F.Supp. 2d).

c. Federal Claims Reporter, West's. [KF125 .C55] (1992 - )
(Abbreviated as Fed. Cl.).

d. United States Claims Court Reporter. West's [KF125 .C55] (1982-1992)
Continued by West's Federal Claims Reporter. (Abbreviated as CL Ct.).

e. United States Tax Cases, CCH.  [KF6280.A2 C58] (1924- )
For recent decisions, USTC advance sheets can be found in the CCH, Standard Federal Tax Reporter. (Abbreviated as USTC).

f. American Federal Tax Reports, RIA. [KF6280 .A2] (1924 - )
Contains federal and state court tax decisions. (Abbreviated as AFTR, AFTR 2d). Also available on Checkpoint, RIA. [Subscription Database (GULC only)]

g. LEXIS: Legal > Area of Law - By Topic > Taxation > Cases and Court Rules > Federal > US Ct. of Federal Claims, Claims Ct., & Ct. of Claims - Tax Cases

h. WESTLAW: FTX-CS

i. Checkpoint, RIA. [Subscription Database (GULC only)]

j. CCH Tax Research Network. [Subscription Database (GULC only)]

k. U.S. Court of Federal Claims website

D.   UNITED STATES COURTS OF APPEALS

The U.S. Courts of Appeals hear appeals from the three lower trial courts, U.S. Tax Court, U.S. District Courts and the U.S. Court of Federal Claims.  All U.S. Courts of Appeals consider appellate cases involving federal statutes, including taxation.  The U.S. Court of Appeals for the Federal Circuit hears appeals from tax cases that originate in the Court of Federal Claims. The other U.S. Courts of Appeals consider cases appealed from the U.S. Tax Court and the U.S. District Courts.

1. LOCATING COURT OF APPEALS TAX DECISIONS

a. Federal Reporter, West's. [KF105 .F4] (1880 - )
(Abbreviated as F. or F.2d or F.3d).

 b. United States Tax Cases, CCH. [KF6280.A2 C58] (1915- )
(Abbreviated as USTC). For recent decisions, USTC advance sheets can be found in the CCH, Standard Federal Tax Reporter.

c. American Federal Tax Reports, RIA. [KF6280 .A2] (1915 - )
(Abbreviated as AFTR & AFTR 2d).

d. LEXIS: Legal > Area of Law - By Topic > Taxation > Cases and Court Rules > Federal > US Courts of Appeal Tax Cases

e. WESTLAW: FTX-CS

f. Checkpoint, RIA. [Subscription Database (GULC only)]

g. CCH Tax Research Network. [Subscription Database (GULC only)]
 

E.  UNITED STATES SUPREME COURT

The Supreme Court is the highest and thus final appellate level for federal trials.  The court hears cases involving federal law, and so includes tax issues.  Citizens have no immediate right to have their case heard by the Supreme Court and must present a Writ of Certiorari for permission to appeal their case before the court. 

1. LOCATING SUPREME COURT TAX DECISIONS

a. United States Reports, US GPO [KF101 .A2]
(Abbreviated as US).

b. Supreme Court Reporter, West's.[KF101 .A32]
(Abbreviated as S.CT.).

c. United States Supreme Court Reports, Lawyers' Edition, Lexis.[KF101 .A312]

d. United States Tax Cases, CCH. [KF6280.A2 C58]
(Abbreviated as USTC). For recent decisions, USTC advance sheets can be found in the CCH, Standard Federal Tax Reporter.

e. American Federal Tax Reports, RIA. [KF6280 .A2] Also available on Checkpoint, RIA. [Subscription Database (GULC only)]
(Abbreviated as AFTR or AFTR 2d).

f. Internal Revenue Bulletin, US GPO [KF6301 .A12]; available electronically on IRS homepage (1996 - present);

g. Internal Revenue Cumulative Bulletin, US GPO [KF6301 .A1;available electronically from LLMC Digital and Hein (GULC only)]

h. LEXIS: Legal > Area of Law - By Topic > Taxation > Cases and Court Rules > Federal > U.S. Supreme Court Cases, Lawyers' Edition - Selected Federal Tax Material

i. WESTLAW: FTX-CS

j. Checkpoint, RIA. [Subscription Database (GULC only)]

k. CCH Tax Research Network. [Subscription Database (GULC only)]

F. CASE DIGESTS

To find case law pertaining to a specific subject, code section or IRS pronouncement the following resources should be consulted.  For federal tax cases, traditional digests such as West's Federal Practice Digest [KF127 .F31 1989] may also be referenced.

1. Standard Federal Tax Reporter, CCH. [KF6365.C58]. Available electronically on the CCH Tax Research Network. [Subscription Database (GULC only)]

2. United States Tax Reporter, RIA. [KF6280.P7 1992] . Also available on Checkpoint, RIA. [Subscription Database (GULC only)]

3. Bulletin Index-Digest System, US GPO [KF6301 .A2]
Digests Supreme Court decisions listed alphabetically by case name.  Also digests adverse Tax Court decisions for which the IRS has announced an acquiescence or nonacquiescance.

G. UPDATING CASE LAW

The Citator volumes are used to update and verify the validity of court decisions by denoting subsequent treatment that may affect the persuasive authority of a case.

1. Standard Federal Tax Reporter - Citator Volumes, CCH. [KF6365.C58]
Arranged by taxpayer name,  CCH citator volumes provides appellate history, parallel citations and references to citing  cases, and IRS pronouncements. Also available on the CCH Tax Research Network. [Subscription Database (GULC only)]. Click "Check Citator" near the top center of the screen.

2. United States Tax Reporter, RIA. [KF6280.P7 1992]
Arranged by taxpayer name, RIA citator volumes provides appellate history, parallel citations and references to citing  cases, and IRS pronouncements. Also available on Checkpoint, RIA. [Subscription Database (GULC only)].

3. Federal Taxes Citator, RIA. [KF6280.5 .P7]
Library cancelled print supplementation of this title in 2007. Within this four volume set, cases are arranged by taxpayer name and provides parallel citations, appellate history and citations to citing cases and agency rulings. Also available on Checkpoint, RIA & Westlaw. [Subscription Database (GULC only)]. Click "Citator 2d."

5. LEXIS:  Shepards's

6. WESTLAW:  Keycite

PERIODICALS

Researching periodical literature is a good way to find commentary and scholarly discussions on tax issues. Because of their currency, newsletters and journals are often the first to print primary tax documentation such as tax treaties, regulations, committee reports and IRS pronouncements. A list of tax related periodical indices and online sources of full-text periodical articles follows:

A. LOCATING PERIODICALS

1. Federal Tax Articles: Income, Estate, Gift, Excise, Employment Taxes, CCH. [KF6335.A6 C58]

2. Index to Federal Tax Articles,  Warren, Gorham and Lamont. [KF6271.G64 1975]

3. The Journal of Taxation Digest, Warren, Gorham & Lamont. [KF6271 .J68] Also available on Checkpoint, RIA. [Subscription Database (GULC only)]

4. Tax Management Portfolios, BNA. [KF6297 .B952]
Tax Management Portfolios offer over 300 spiral portfolios that provide analysis of complex tax issues and includes working papers and bibliographies to additional resources. Also available in BNA's Federal/Foreign Tax Library . [Subscription Database (GULC only)]

5. Index to Legal Periodicals and Books, H.W. Wilson Co. [KF8 .I4] Also available on Lexis, Westlaw and through the Library's web page (listed as Legal Periodicals and Books) [Subscription Database (GULC only)].

6. Legal Resources Index, Available on Lexis, Westlaw and through the Library's webpage (listed as LegalTrac). [Subscription Database (GULC only)].

7. LEXIS: Legal > Area of Law - By Topic > Taxation > Law Reviews & Journals > Tax Law Review Articles, Combined

8. WESTLAW: TX-TP

9. Checkpoint, RIA. [Subscription Database (GULC only)]
Offers the full text of RIA periodicals such as Federal Taxes Weekly, Tax Notes Today, Journal of Corporate Taxation, and others.

10. CCH Tax Research Network. [Subscription Database (GULC only)]
Offers the full text of CCH periodicals such as Federal Tax Day, Journal of Retirement Planning, Federal Estate and Gift Tax Report Letter, and others.

IRS Procedures and Policies

IRS procedures and policies are contained within the Internal Revenue Manual, an official IRS publication available on CD-ROM in Media Services. This publication contains the text of IRS internal policies, operation procedures, instructions and guidelines. When revisions or amendments are made the IRS issues Manual Supplements.  Supplements are located at the end of their corresponding chapter.  If the contents of the Supplement involve more than one section of the Manual, the Supplement is printed in full text after the primary chapter.  Cross references are made from subsequent chapters to the full text. Commerce Clearinghouse publishes an unofficial version of the Manual in two looseleaf sets: Internal Revenue Manual: Administration (KF6301.A6 I5 1973) and Internal Revenue Manual: Audit (KF6301.A6 I57 1977). This unofficial version of the Manual is also available electronically through the CCH Tax Research Network. [Subscription Database (GULC only)]

IRS Publications

1. Internal Revenue Manual [Unofficial CCH loose-leaf KF6301.A6 I5 1973 & KF6301.A6 I57 1977; also available electronically through the CCH Tax Research Network.]

2. IRS.gov - Official website for the IRS.

3. WESTLAW: FTX-IRSPUBS

4. LEXIS: Legal > Area of Law - By Topic > Taxation > Administrative Materials & Regulations > Federal > Agency Publications

5. BNA's Federal/Foreign Tax Library . [Subscription Database (GULC only)]

6. Checkpoint, RIA. [Subscription Database (GULC only)]

7. CCH Tax Research Network. [Subscription Database (GULC only)]

IRS Forms

A. LOCATING IRS FORMS

1. IRS.gov - Official website for the IRS. Official forms back to 1990

Internet Sources

A. IRS.gov -
The official site of the IRS, offers forms, publications, notices news, regulations, statutes and statistics.

B. Tax Stats from the IRS -
Includes data, reports, and tables from the IRS that describe and measure elements of the US Tax System.

C. Transactional Records Access Clearinghouse / IRS -
(TRAC) is a data gathering, data research and data distribution organization associated with Syracuse University.  TRAC provides information about the enforcement activities of various federal government agencies, including the IRS.  Offers IRS statistics, trends and historical information.

D. ABA Tax Section -
Extensive meta-index with links to Internet sources for primary tax materials, state and international tax sites and more.

E. Tax and Accounting Sites Directory -
Tax meta-index to federal, tax, and International primary tax and accounting materials on the web.  Also includes links to forms, publications and news.

Last Updated: 10/14/2009 (LAS)

)
Special thanks to Tracey Bridgman, former Reference & Faculty Services Librarian, Georgetown University Law Library and Professor Victor T. Thuronyi, Georgetown University Law Center.