FEDERAL TAX RESEARCHProfessor Lisa Smith-ButlerAdvanced Legal ResearchFall 2016

bull Many thanks to Professor Gail Levin Richmond Professor Emeritus at Nova Southeastern University Shepard Broad Law Center for guiding me through the thicket of tax research

FEDERAL TAX RESEARCH

bull The US Constitution article 1 Sec8 cl 1 empowers the US Congress to bull lay and collect Taxes Duties bull Imposts and Excises and to pay bull the debts and provide for the bull common Defense and generalbull Welfare of the United States bull But all Duties Imposts and bull Excises shall be uniform bull Throughout the United States

bull Many thanks to Professor Gail Levin Richmond Professor Emeritus at Nova Southeastern University Shepard Broad Law Center for guiding me through the thicket of tax research

FEDERAL TAX RESEARCH

bull The US Constitution article 1 Sec8 cl 1 empowers the US Congress to bull lay and collect Taxes Duties bull Imposts and Excises and to pay bull the debts and provide for the bull common Defense and generalbull Welfare of the United States bull But all Duties Imposts and bull Excises shall be uniform bull Throughout the United States

FEDERAL TAX RESEARCH

bull The US Constitution article 1 Sec8 cl 1 empowers the US Congress to bull lay and collect Taxes Duties bull Imposts and Excises and to pay bull the debts and provide for the bull common Defense and generalbull Welfare of the United States bull But all Duties Imposts and bull Excises shall be uniform bull Throughout the United States

HOW DO I START A TAX RESEARCH PROJECT

bull If you have a citation or popular name go directly to Title 26 (Internal Revenue Code) of the Code

bull If you know very little about the topic and want to begin to familiarize yourself select a secondary resource to assist

SECONDARY SOURCES

bull Secondary sources that will help explain tax research materials and techniques includebull Barkan Steve ed et al Federal Tax Research in

Fundamentals of Legal Research 9th ed (New York Foundation Press 2009) KF 240F85 2009

bull Richmond Gail Levin Federal Tax Research Guide to Materials and Techniques 8th ed (New York Foundation Press 2010) KF 241 T38 R53 2010

PRIMARY SOURCES OF AUTHORITY

bull As with every other subject that we have examined this semester there are three primary sources of authority with regards to federal taxation

bull Primary sources of federal tax authority includebull statutes ie legislation drafted by the US Congressbull regulations promulgated under either a delegation of

legislative power to the Treasury Department or an exercise of executive power by the Internal Revenue Service (IRS)

bull cases decided initially by the Tax Court a US District Court the Court of Federal Claims or a US Bankruptcy Court Those decisions can be appealed to the appropriate US Court of Appeals and ultimately the US Supreme Court

STATUTESbull Legislation enacted by the US Congress regarding taxes is

published (codified or published in a subject arrangement) in Title 26 of the United States Code Title 26 can also be cited as the IRC Internal Revenue Code

bull The USC can be found inbull in print publications by GPO West and Lexisbull online at no charge at FDsys bull online at fee sites such as WestlawNext Lexis Advance

Bloomberg Law and HeinOnlinebull in commercial publications print and electronic such as

Bloomberg BNArsquos tax products CCHrsquos Standard Federal Tax Reporter Mertenrsquos and RIA Checkpoint

SECONDARY SOURCES

bull Secondary sources that will help explain tax research materials and techniques includebull Barkan Steve ed et al Federal Tax Research in

Fundamentals of Legal Research 9th ed (New York Foundation Press 2009) KF 240F85 2009

bull Richmond Gail Levin Federal Tax Research Guide to Materials and Techniques 8th ed (New York Foundation Press 2010) KF 241 T38 R53 2010

PRIMARY SOURCES OF AUTHORITY

bull As with every other subject that we have examined this semester there are three primary sources of authority with regards to federal taxation

bull Primary sources of federal tax authority includebull statutes ie legislation drafted by the US Congressbull regulations promulgated under either a delegation of

legislative power to the Treasury Department or an exercise of executive power by the Internal Revenue Service (IRS)

bull cases decided initially by the Tax Court a US District Court the Court of Federal Claims or a US Bankruptcy Court Those decisions can be appealed to the appropriate US Court of Appeals and ultimately the US Supreme Court

STATUTESbull Legislation enacted by the US Congress regarding taxes is

published (codified or published in a subject arrangement) in Title 26 of the United States Code Title 26 can also be cited as the IRC Internal Revenue Code

bull The USC can be found inbull in print publications by GPO West and Lexisbull online at no charge at FDsys bull online at fee sites such as WestlawNext Lexis Advance

Bloomberg Law and HeinOnlinebull in commercial publications print and electronic such as

Bloomberg BNArsquos tax products CCHrsquos Standard Federal Tax Reporter Mertenrsquos and RIA Checkpoint

PRIMARY SOURCES OF AUTHORITY

bull As with every other subject that we have examined this semester there are three primary sources of authority with regards to federal taxation

bull Primary sources of federal tax authority includebull statutes ie legislation drafted by the US Congressbull regulations promulgated under either a delegation of

legislative power to the Treasury Department or an exercise of executive power by the Internal Revenue Service (IRS)

bull cases decided initially by the Tax Court a US District Court the Court of Federal Claims or a US Bankruptcy Court Those decisions can be appealed to the appropriate US Court of Appeals and ultimately the US Supreme Court

STATUTESbull Legislation enacted by the US Congress regarding taxes is

published (codified or published in a subject arrangement) in Title 26 of the United States Code Title 26 can also be cited as the IRC Internal Revenue Code

bull The USC can be found inbull in print publications by GPO West and Lexisbull online at no charge at FDsys bull online at fee sites such as WestlawNext Lexis Advance

Bloomberg Law and HeinOnlinebull in commercial publications print and electronic such as

Bloomberg BNArsquos tax products CCHrsquos Standard Federal Tax Reporter Mertenrsquos and RIA Checkpoint

STATUTESbull Legislation enacted by the US Congress regarding taxes is

published (codified or published in a subject arrangement) in Title 26 of the United States Code Title 26 can also be cited as the IRC Internal Revenue Code

bull The USC can be found inbull in print publications by GPO West and Lexisbull online at no charge at FDsys bull online at fee sites such as WestlawNext Lexis Advance

Bloomberg Law and HeinOnlinebull in commercial publications print and electronic such as

Bloomberg BNArsquos tax products CCHrsquos Standard Federal Tax Reporter Mertenrsquos and RIA Checkpoint

SELECTED COMMERCIAL TAX SPECIALTY PUBLICATIONS

bull BNA Daily Tax Report bull BNA Tax amp Accounting Centerbull CCH Standard Federal Tax Reporterbull HeinOnline Tax Librariesbull LexisAdvance Tax Librarybull RIA Checkpointbull Tax Analystsbull WestlawNext Tax Library

BLOOMBERG BNAbull Bloomberg BNA is best known for its TAX MANAGEMENT

PORTFOLIOS as well as its current awareness resource the DAILY

TAX REPORT

BNA DAILY TAX REPORT

BNA TAX PORTFOLIOS VIA THE TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX REPORTER

bull SFTR can be considered one stop shopping because the researcher can access thebull text of the IRCbull selected legislative history pertaining to IRC provisionsbull committee reportsbull regulationsbull annotations amp bull commentary

FINDING CCHrsquoS STANDARD FEDERAL TAX REPORTER

THE CODE PROVISIONS

LEGISLATIVE HISTORY OF THE CODE

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

BLOOMBERG BNAbull Bloomberg BNA is best known for its TAX MANAGEMENT

PORTFOLIOS as well as its current awareness resource the DAILY

TAX REPORT

BNA DAILY TAX REPORT

BNA TAX PORTFOLIOS VIA THE TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX REPORTER

bull SFTR can be considered one stop shopping because the researcher can access thebull text of the IRCbull selected legislative history pertaining to IRC provisionsbull committee reportsbull regulationsbull annotations amp bull commentary

FINDING CCHrsquoS STANDARD FEDERAL TAX REPORTER

THE CODE PROVISIONS

LEGISLATIVE HISTORY OF THE CODE

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

BNA DAILY TAX REPORT

BNA TAX PORTFOLIOS VIA THE TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX REPORTER

bull SFTR can be considered one stop shopping because the researcher can access thebull text of the IRCbull selected legislative history pertaining to IRC provisionsbull committee reportsbull regulationsbull annotations amp bull commentary

FINDING CCHrsquoS STANDARD FEDERAL TAX REPORTER

THE CODE PROVISIONS

LEGISLATIVE HISTORY OF THE CODE

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

BNA TAX PORTFOLIOS VIA THE TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX REPORTER

bull SFTR can be considered one stop shopping because the researcher can access thebull text of the IRCbull selected legislative history pertaining to IRC provisionsbull committee reportsbull regulationsbull annotations amp bull commentary

FINDING CCHrsquoS STANDARD FEDERAL TAX REPORTER

THE CODE PROVISIONS

LEGISLATIVE HISTORY OF THE CODE

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

CCH STANDARD FEDERAL TAX REPORTER

bull SFTR can be considered one stop shopping because the researcher can access thebull text of the IRCbull selected legislative history pertaining to IRC provisionsbull committee reportsbull regulationsbull annotations amp bull commentary

FINDING CCHrsquoS STANDARD FEDERAL TAX REPORTER

THE CODE PROVISIONS

LEGISLATIVE HISTORY OF THE CODE

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

FINDING CCHrsquoS STANDARD FEDERAL TAX REPORTER

THE CODE PROVISIONS

LEGISLATIVE HISTORY OF THE CODE

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

THE CODE PROVISIONS

LEGISLATIVE HISTORY OF THE CODE

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

LEGISLATIVE HISTORY OF THE CODE

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

REGULATIONS

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

CCH EXPLANATIONS

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

ANNOTATIONS

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

HEINONLINEbull In addition to the Seidman legislative histories Hein

Online also provides access to tax and economic reform legislative histories as well as early tax and economic reform books

bull The IRC from 1909-1950 is also available via Hein Online

bull Hein recently added the Tax Archive Foundation to its Tax Library

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

HEINONLINE

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

LEXISADVANCE

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

WESTLAWNEXT

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

LEGISLATIVE HISTORY SPECIALIZED TAX RESOURCES

bull In addition to the usual sources for compiling a federal legislative history specialized tax resources exist

bull Some of these specialized resources arebull Seidmanrsquos Legislative History of Federal Income Tax

laws 1861-1938bull Seidmanrsquos Legislative History of Federal Income and

Excess Profit Laws 1938-1953 bull Seidmanrsquos Legislative History of Excess Profit Tax Laws

ampbull Compiled Tax Legislative Histories by Bernard Reams

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

REGULATIONS amp IRS PRONOUNCEMENTS

bull The Treasury Department promulgates and issues regulations pertaining to the tax code while the Internal Revenue Service makes pronouncements about pending situations of individualcorporate taxpayers and the tax code

bull These regulations pending regulations and various pronouncements are published in a variety of sources which we will now discuss

TREASURY DEPARTMENT

REGULATIONSbull Temporary and final regulations

promulgated by the Treasury Department are also known as Treasury Decisions (TD)

bull As with all regulations these final regulations are initially published in the Federal Register (FR) and then codified into Title 26 of the Code of Federal Regulations (CFR)

bull Pending regulations ie proposed TDs are published in the Federal Register as are all pending federal regulations

IRS PRONOUNCEMENTSbull The IRS issues pronouncements that are both

officially published as well as unofficially publishedbull Officially published pronouncements include

bull Revenue Rulings (RR)bull Revenue Procedures (RP) ampbull Notices amp Announcements

bull These pronouncements do have legal significance for taxpayers

IRS PRONOUNCEMENTS

bull In addition to making and publishing official announcements the IRS also makes announcements that it publically releases but does not officially publish

bull These includebull Private Letter Rulings (PLR)bull Technical Advice Memorandum (TAM)bull Actions on Decision (AOD)bull General Counsel Memoranda (GCM)bull Internal Revenue Manual (IRM)bull Field Service Advice (FSA)bull Service Center Advice (SCA)bull Chief Counsel Advice (CCA)bull Chief Counsel Bulletins bull Litigation Guideline Memoranda (LGM)bull Industry Specialization Program (ISP)

OFFICIAL IRS PRONOUNCEMENTS WHERE

CAN THEY BE FOUND

bull Revenue Rulings (RR) are issued by the IRS to deal with particular factual situations presented by a taxpayer If the IRS determines that the ruling is of general interest it is published in the Internal Revenue Bulletin and Cumulative Bulletin The Cumulative Bulletin ceased publication in 2008 merging into the Internal Revenue Bulletin

bull Revenue Rulings can be relied upon by taxpayers in similar factual situations

IRS PRONOUNCEMENTSbull The IRS issues pronouncements that are both

officially published as well as unofficially publishedbull Officially published pronouncements include

bull Revenue Rulings (RR)bull Revenue Procedures (RP) ampbull Notices amp Announcements

bull These pronouncements do have legal significance for taxpayers

IRS PRONOUNCEMENTS

bull In addition to making and publishing official announcements the IRS also makes announcements that it publically releases but does not officially publish

bull These includebull Private Letter Rulings (PLR)bull Technical Advice Memorandum (TAM)bull Actions on Decision (AOD)bull General Counsel Memoranda (GCM)bull Internal Revenue Manual (IRM)bull Field Service Advice (FSA)bull Service Center Advice (SCA)bull Chief Counsel Advice (CCA)bull Chief Counsel Bulletins bull Litigation Guideline Memoranda (LGM)bull Industry Specialization Program (ISP)

OFFICIAL IRS PRONOUNCEMENTS WHERE

CAN THEY BE FOUND

bull Revenue Rulings (RR) are issued by the IRS to deal with particular factual situations presented by a taxpayer If the IRS determines that the ruling is of general interest it is published in the Internal Revenue Bulletin and Cumulative Bulletin The Cumulative Bulletin ceased publication in 2008 merging into the Internal Revenue Bulletin

bull Revenue Rulings can be relied upon by taxpayers in similar factual situations

IRS PRONOUNCEMENTS

bull In addition to making and publishing official announcements the IRS also makes announcements that it publically releases but does not officially publish

bull These includebull Private Letter Rulings (PLR)bull Technical Advice Memorandum (TAM)bull Actions on Decision (AOD)bull General Counsel Memoranda (GCM)bull Internal Revenue Manual (IRM)bull Field Service Advice (FSA)bull Service Center Advice (SCA)bull Chief Counsel Advice (CCA)bull Chief Counsel Bulletins bull Litigation Guideline Memoranda (LGM)bull Industry Specialization Program (ISP)

OFFICIAL IRS PRONOUNCEMENTS WHERE

CAN THEY BE FOUND

bull Revenue Rulings (RR) are issued by the IRS to deal with particular factual situations presented by a taxpayer If the IRS determines that the ruling is of general interest it is published in the Internal Revenue Bulletin and Cumulative Bulletin The Cumulative Bulletin ceased publication in 2008 merging into the Internal Revenue Bulletin

bull Revenue Rulings can be relied upon by taxpayers in similar factual situations

OFFICIAL IRS PRONOUNCEMENTS WHERE

CAN THEY BE FOUND

bull Revenue Rulings (RR) are issued by the IRS to deal with particular factual situations presented by a taxpayer If the IRS determines that the ruling is of general interest it is published in the Internal Revenue Bulletin and Cumulative Bulletin The Cumulative Bulletin ceased publication in 2008 merging into the Internal Revenue Bulletin

bull Revenue Rulings can be relied upon by taxpayers in similar factual situations

REVENUE PROCEDURES amp PROCEDURAL RULES (RP)

bull These are publications in the Internal Revenue Bulletin of IRS practices and procedures Prior to 2009 they were also published in the Cumulative Bulletin

bull They are arranged by year of publication in chronological order

bull As with Revenue Rulings other taxpayers can rely upon Revenue Procedures to avoid ldquosubstantial understatement penaltiesrdquo

OFFICIALLY PUBLISHED IRS PRONOUNCEMENTS

bull Notices Announcements amp Other Itemsbull These are officially released by the IRS and published

in the Internal Revenue Bulletin

INTERNAL REVENUE BULLETIN

OFFICIAL PRONOUNCEMENTS OF THE IRS

bull Official pronouncements by the IRS are published in an official IRS publications known as the Internal Revenue Bulletin Prior to 2009 they were also included in the Cumulative Bulletin

bull They are also published commercially in CCH and RIA Checkpoint

OFFICIAL PRONOUNCEMENTS OF THE IRS

bull Official pronouncements by the IRS are published in an official IRS publications known as the Internal Revenue Bulletin Prior to 2009 they were also included in the Cumulative Bulletin

bull They are also published commercially in CCH and RIA Checkpoint

RELEASED IRS PRONOUNCEMENTS

bull The IRS also publically releases pronouncements such as TAMs AODs PLRs and other publications that the IRS does not consider to be ldquoofficially publishedrdquo

bull The IRS does not consider itself to be bound by these pronouncements to taxpayers as a group

PRIVATE LETTER RULINGS

bull Private Letter Rulings (PLR) are issued by the IRS to private taxpayers to provide guidance regarding a particular IRS policy as applied to a given set of factual circumstances

bull The taxpayer receives this ruling before it is publically released to others

bull While illustrative of IRS policy these PLRs cannot be relied upon by taxpayers other than the one to whom the ruling was issued

ACTIONS ON DECISIONSbull Actions on Decisions demonstrate the reasons why

the IRS chooses not to appeal an adverse decision issued against it by a trial level court

TECHNICAL ADVICE MEMORANDA amp GENERAL

COUNSEL MEMORANDAbull Technical Advice Memoranda (TAMs) are issued by

the IRS in response to ldquoIRS requests arising out of tax return examinationsrdquobull See Richmond Gail Levin Federal Tax Research in

Fundamentals of Legal Researchbull General Counsel Memoranda (GCMs) come from the

Office of General Counsel of the IRS They provide the reasoning and authority relied upon by the IRS when issuing PLRs RRs and RPs

WHERE CAN WE FIND THE RELEASED YET NOT OFFICIALLY PUBLISHED IRS

PRONOUNCEMENTS

bull Bloomberg BNA Tax amp Accounting Centerbull CCH Standard Federal Tax Reporterbull Internal Revenue Bulletinbull Lexis Advancebull Tax Analystsbull Westlaw Next

BLOOMBERGBNA TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX

REPORTER

INTERNAL REVENUE BULLETIN

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

PRIVATE LETTER RULINGS

bull Private Letter Rulings (PLR) are issued by the IRS to private taxpayers to provide guidance regarding a particular IRS policy as applied to a given set of factual circumstances

bull The taxpayer receives this ruling before it is publically released to others

bull While illustrative of IRS policy these PLRs cannot be relied upon by taxpayers other than the one to whom the ruling was issued

ACTIONS ON DECISIONSbull Actions on Decisions demonstrate the reasons why

the IRS chooses not to appeal an adverse decision issued against it by a trial level court

TECHNICAL ADVICE MEMORANDA amp GENERAL

COUNSEL MEMORANDAbull Technical Advice Memoranda (TAMs) are issued by

the IRS in response to ldquoIRS requests arising out of tax return examinationsrdquobull See Richmond Gail Levin Federal Tax Research in

Fundamentals of Legal Researchbull General Counsel Memoranda (GCMs) come from the

Office of General Counsel of the IRS They provide the reasoning and authority relied upon by the IRS when issuing PLRs RRs and RPs

WHERE CAN WE FIND THE RELEASED YET NOT OFFICIALLY PUBLISHED IRS

PRONOUNCEMENTS

bull Bloomberg BNA Tax amp Accounting Centerbull CCH Standard Federal Tax Reporterbull Internal Revenue Bulletinbull Lexis Advancebull Tax Analystsbull Westlaw Next

BLOOMBERGBNA TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX

REPORTER

INTERNAL REVENUE BULLETIN

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

ACTIONS ON DECISIONSbull Actions on Decisions demonstrate the reasons why

the IRS chooses not to appeal an adverse decision issued against it by a trial level court

TECHNICAL ADVICE MEMORANDA amp GENERAL

COUNSEL MEMORANDAbull Technical Advice Memoranda (TAMs) are issued by

the IRS in response to ldquoIRS requests arising out of tax return examinationsrdquobull See Richmond Gail Levin Federal Tax Research in

Fundamentals of Legal Researchbull General Counsel Memoranda (GCMs) come from the

Office of General Counsel of the IRS They provide the reasoning and authority relied upon by the IRS when issuing PLRs RRs and RPs

WHERE CAN WE FIND THE RELEASED YET NOT OFFICIALLY PUBLISHED IRS

PRONOUNCEMENTS

bull Bloomberg BNA Tax amp Accounting Centerbull CCH Standard Federal Tax Reporterbull Internal Revenue Bulletinbull Lexis Advancebull Tax Analystsbull Westlaw Next

BLOOMBERGBNA TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX

REPORTER

INTERNAL REVENUE BULLETIN

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

TECHNICAL ADVICE MEMORANDA amp GENERAL

COUNSEL MEMORANDAbull Technical Advice Memoranda (TAMs) are issued by

the IRS in response to ldquoIRS requests arising out of tax return examinationsrdquobull See Richmond Gail Levin Federal Tax Research in

Fundamentals of Legal Researchbull General Counsel Memoranda (GCMs) come from the

Office of General Counsel of the IRS They provide the reasoning and authority relied upon by the IRS when issuing PLRs RRs and RPs

WHERE CAN WE FIND THE RELEASED YET NOT OFFICIALLY PUBLISHED IRS

PRONOUNCEMENTS

bull Bloomberg BNA Tax amp Accounting Centerbull CCH Standard Federal Tax Reporterbull Internal Revenue Bulletinbull Lexis Advancebull Tax Analystsbull Westlaw Next

BLOOMBERGBNA TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX

REPORTER

INTERNAL REVENUE BULLETIN

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

WHERE CAN WE FIND THE RELEASED YET NOT OFFICIALLY PUBLISHED IRS

PRONOUNCEMENTS

bull Bloomberg BNA Tax amp Accounting Centerbull CCH Standard Federal Tax Reporterbull Internal Revenue Bulletinbull Lexis Advancebull Tax Analystsbull Westlaw Next

BLOOMBERGBNA TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX

REPORTER

INTERNAL REVENUE BULLETIN

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

BLOOMBERGBNA TAX amp ACCOUNTING CENTER

CCH STANDARD FEDERAL TAX

REPORTER

INTERNAL REVENUE BULLETIN

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

CCH STANDARD FEDERAL TAX

REPORTER

INTERNAL REVENUE BULLETIN

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

INTERNAL REVENUE BULLETIN

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

LEXISADVANCE

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

WESTLAWNEXT

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

CASESbull After locating the applicable statutory provision and

related regulations cases can then be reviewed to understand how courts are interpreting the IRC

bull Where do tax cases originatebull US Tax Court bull US Bankruptcy Courtbull Court of Federal Claimsbull US District Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

CASES IN TAX COURTbull Taxpayers who can not or will not pay disputed tax

bills with the IRS proceed to the US Tax Court to resolve their dispute

bull The official publication for US Tax Court decisions is United States Tax Court Reports

bull Commercial publications of Tax Court decisions include the CCH Tax Court Reporter amp RIA Tax Court

UNITED STATES TAX COURT

TAX DECISIONS IN BANKRUPTCY COURT amp THE COURT OF FEDERAL CLAIMS

bull Decisions regarding taxes issued in a US Bankruptcy Court after 1980 are published in the subject publication Bankruptcy Reporter

bull Decisions from the US Court of Federal Claims are now published in the US Court of Claims Reports

TAX DECISIONS IN BANKRUPTCY COURT amp THE COURT OF FEDERAL CLAIMS

bull Decisions regarding taxes issued in a US Bankruptcy Court after 1980 are published in the subject publication Bankruptcy Reporter

bull Decisions from the US Court of Federal Claims are now published in the US Court of Claims Reports

TAX DECISIONS IN US DISTRICT COURTS

bull Provided a tax payer can and does pay the disputed tax to the IRS the tax payer can then sue the IRS for a refund in the appropriate US federal district court

bull Before 1932 these decisions were published in the FEDERAL REPORTER

bull After 1932 these decisions were published in the FEDERAL SUPPLEMENT

COMMERCIAL PUBLICATIONS

bull Decisions involving tax disputes are published commercially inbull AMERICAN FEDERAL TAX REPORTSbull CCH STANDARD FEDERAL TAX REPORTERbull CCH TAX COURT REPORTER

BLOOMBERGBNA TAX PRACTICE CENTER

CCH STANDARD FEDERAL TAX

REPORTER

APPELLATE DECISIONS INVOLVING TAX

bull Decisions from the Tax Court US District Court US Bankruptcy Court and Court of Federal Claims can be appealed to the appropriate Circuit Court and ultimately to the US Supreme Court

bull Circuit Court decisions are published in the Federal Reporter while US Supreme Court decisions are published in the US Reports

UPDATING TAX MATERIALS

bull Tax citators exist enabling tax researchers to update their materials

bull Citators arebull Shepards Federal Tax Citationsbull CCH Standard Federal Tax Citator

CCH FEDERAL TAX CITATOR

LOOSE LEAFS amp TREATISES

bull Several loose leaf services subject specific to tax do exist and includebull Bloomberg BNA Tax Management Portfoliosbull CCH Standard Federal Tax Reporterbull Mertenrsquos Law of Federal Income Taxationbull RIA Federal Tax Coordinator

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

COMMERCIAL PUBLICATIONS

bull Decisions involving tax disputes are published commercially inbull AMERICAN FEDERAL TAX REPORTSbull CCH STANDARD FEDERAL TAX REPORTERbull CCH TAX COURT REPORTER

BLOOMBERGBNA TAX PRACTICE CENTER

CCH STANDARD FEDERAL TAX

REPORTER

APPELLATE DECISIONS INVOLVING TAX

bull Decisions from the Tax Court US District Court US Bankruptcy Court and Court of Federal Claims can be appealed to the appropriate Circuit Court and ultimately to the US Supreme Court

bull Circuit Court decisions are published in the Federal Reporter while US Supreme Court decisions are published in the US Reports

UPDATING TAX MATERIALS

bull Tax citators exist enabling tax researchers to update their materials

bull Citators arebull Shepards Federal Tax Citationsbull CCH Standard Federal Tax Citator

CCH FEDERAL TAX CITATOR

LOOSE LEAFS amp TREATISES

bull Several loose leaf services subject specific to tax do exist and includebull Bloomberg BNA Tax Management Portfoliosbull CCH Standard Federal Tax Reporterbull Mertenrsquos Law of Federal Income Taxationbull RIA Federal Tax Coordinator

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

BLOOMBERGBNA TAX PRACTICE CENTER

CCH STANDARD FEDERAL TAX

REPORTER

APPELLATE DECISIONS INVOLVING TAX

bull Decisions from the Tax Court US District Court US Bankruptcy Court and Court of Federal Claims can be appealed to the appropriate Circuit Court and ultimately to the US Supreme Court

bull Circuit Court decisions are published in the Federal Reporter while US Supreme Court decisions are published in the US Reports

UPDATING TAX MATERIALS

bull Tax citators exist enabling tax researchers to update their materials

bull Citators arebull Shepards Federal Tax Citationsbull CCH Standard Federal Tax Citator

CCH FEDERAL TAX CITATOR

LOOSE LEAFS amp TREATISES

bull Several loose leaf services subject specific to tax do exist and includebull Bloomberg BNA Tax Management Portfoliosbull CCH Standard Federal Tax Reporterbull Mertenrsquos Law of Federal Income Taxationbull RIA Federal Tax Coordinator

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

CCH STANDARD FEDERAL TAX

REPORTER

APPELLATE DECISIONS INVOLVING TAX

bull Decisions from the Tax Court US District Court US Bankruptcy Court and Court of Federal Claims can be appealed to the appropriate Circuit Court and ultimately to the US Supreme Court

bull Circuit Court decisions are published in the Federal Reporter while US Supreme Court decisions are published in the US Reports

UPDATING TAX MATERIALS

bull Tax citators exist enabling tax researchers to update their materials

bull Citators arebull Shepards Federal Tax Citationsbull CCH Standard Federal Tax Citator

CCH FEDERAL TAX CITATOR

LOOSE LEAFS amp TREATISES

bull Several loose leaf services subject specific to tax do exist and includebull Bloomberg BNA Tax Management Portfoliosbull CCH Standard Federal Tax Reporterbull Mertenrsquos Law of Federal Income Taxationbull RIA Federal Tax Coordinator

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

APPELLATE DECISIONS INVOLVING TAX

bull Decisions from the Tax Court US District Court US Bankruptcy Court and Court of Federal Claims can be appealed to the appropriate Circuit Court and ultimately to the US Supreme Court

bull Circuit Court decisions are published in the Federal Reporter while US Supreme Court decisions are published in the US Reports

UPDATING TAX MATERIALS

bull Tax citators exist enabling tax researchers to update their materials

bull Citators arebull Shepards Federal Tax Citationsbull CCH Standard Federal Tax Citator

CCH FEDERAL TAX CITATOR

LOOSE LEAFS amp TREATISES

bull Several loose leaf services subject specific to tax do exist and includebull Bloomberg BNA Tax Management Portfoliosbull CCH Standard Federal Tax Reporterbull Mertenrsquos Law of Federal Income Taxationbull RIA Federal Tax Coordinator

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

UPDATING TAX MATERIALS

bull Tax citators exist enabling tax researchers to update their materials

bull Citators arebull Shepards Federal Tax Citationsbull CCH Standard Federal Tax Citator

CCH FEDERAL TAX CITATOR

LOOSE LEAFS amp TREATISES

bull Several loose leaf services subject specific to tax do exist and includebull Bloomberg BNA Tax Management Portfoliosbull CCH Standard Federal Tax Reporterbull Mertenrsquos Law of Federal Income Taxationbull RIA Federal Tax Coordinator

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

CCH FEDERAL TAX CITATOR

LOOSE LEAFS amp TREATISES

bull Several loose leaf services subject specific to tax do exist and includebull Bloomberg BNA Tax Management Portfoliosbull CCH Standard Federal Tax Reporterbull Mertenrsquos Law of Federal Income Taxationbull RIA Federal Tax Coordinator

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

LOOSE LEAFS amp TREATISES

bull Several loose leaf services subject specific to tax do exist and includebull Bloomberg BNA Tax Management Portfoliosbull CCH Standard Federal Tax Reporterbull Mertenrsquos Law of Federal Income Taxationbull RIA Federal Tax Coordinator

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

NEWSLETTERSCURRENT AWARENESS

bull BNA Daily Tax Reportbull Tax Analysts Tax Notes Today

DAILY TAX REPORT

BLOGS TAXPROF BLOG

DAILY TAX REPORT

BLOGS TAXPROF BLOG

BLOGS TAXPROF BLOG

FORMS CHECK OUT WWWIRSGOV

QUESTIONSbull Stop by the Reference

Desk or check out Gail Levin Richmondrsquos TAX RESEARCH TECHNIQUES

bull Email us referencecharlestonlawedu

bull Call us 8433774020