Federal Tax Research: Researching Tax Law

1) Secondary Sources

• These provide an overview of the particular topic and include references to other titles and IRS materials

Look for Tax Treatises or Reporters

• Tax treatises are written by experts in specific areas of tax law and are meant to be comprehensive, up-to-date treatments of the topic.
• Search one of the tax reporting services using keywords to find an overview of the topic. Also consult the tables of contents and the indexes. A few titles available in the subscription databases:
  • Federal Tax Practice & Procedure (Lexis)
  • Federal Tax Coordinator 2d (Westlaw)
  • The Law of Tax-Exempt Organizations 12^th ed. (Bloomberg Law)
  • Mertens Law of Federal Income Taxation (Westlaw)
  • United States Tax Reporter (Westlaw)

2) Pertinent code section - Internal Revenue Code (Title 26 U.S. Code)

• Begin with the Internal Revenue Code, using the index and browsing the table of contents in order to locate the most relevant code section
• Some titles like the United States Tax Reporter are arranged by Internal Revenue Code Section. This emphasizes the primacy of the Code as the basis for tax law. Administrative sources that interpret and explain the Code include Treasury Department and IRS Regulations, Revenue Rulings and other pronouncements. These documents are published in the Internal Revenue Bulletin and cumulated the Cumulative Bulletin.

3)  Corresponding Treasury Regulations

• Most section of the IRC have at least one corresponding treasury regulation

4) Relevant Court Cases

• Judicial sources of tax law consist of the various court rulings on federal tax matters.
• Use the subscription research services to find these case, for instance:
  • Tax Court Memorandum Decisions (Lexis)
  • United States Tax Court Cases (Westlaw)

5) Revenue Rulings and Procedures

• Revenue ruling and procedures apply the code to situations where the IRS feels that guidance is needed.

6) Other Administrative Documents

• Locating administrative documents can be challenging and is divided into the following two categories:

1. Public information - these are documents that the agency wants the public and tax professionals to be aware of, including announcements and notices. the authority of these documents will vary.
2. Internal documents - these documents are available because of the Freedom of Information Act, and while they illustrate a position taken by the IRS, the service typically does not consider these to be authoritative. The private letter rulings are the most well known of these documents. Most of these documents are readily available on the IRS website,

7) Search Current Tax News Sources for the Latest Developments

• You should check these sources to make sure you are aware of any recent or prospective developments affecting your area of inquiry. See the Current Awareness box under the Research Services tab.

8) Find In-depth Journal Articles and Tax Planning Materials

• There are many specialized tax journals that regularly publish in-depth articles on tax topics especially in areas where the tax law has recently changed or is unsettled. Examples include:
  • Tax Advisor-Federal Topical (Lexis)
  • Journal of Taxation (Westlaw)
  • Tax Analyst Journals
    • Tax Analysts specializes in analyzing complex tax issues.
  • You can search for articles in these journals in Lexis or Westlaw or by using one of the general databases such as Business Source Complete or Mercer Libraries journal search. Tax planning services are written for tax practitioners to help them advise clients.