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Federal Tax Research

Access

The call numbers on this page link to library catalog records, which provide information about location, availability, and currency of each item in the Ross-Blakley Law Library.

Westlaw and LexisNexis links will take you to the specified database if you have a password. These links work better if you are already logged in. The College of Law provides Westlaw and LexisNexis passwords to its law faculty, staff, and students.

BNA databases are available on computers in the Ross-Blakley Law Library. College of Law faculty, staff, and students can obtain a password from a reference librarian or via ASURITE. HeinOnline and CCH databases are available on the ASU computer network, including remote access for ASU faculty, staff, and students.

Links to commercial databases will open in a new tab or window.

Research Guides

For more information on tax research topics, check out one of the following research guides.

  • Cummings, Legal Research in Federal Taxation, 109 Tax Notes 335 (2005). K24 .A9 and on LexisNexis: 109 Tax Notes 335.
  • Richmond, Federal Tax Research: Guide to Materials and Techniques, 7th ed. KF241.T38R5 2007 (current edition on Reserve).
  • U.S. Federal Tax Research, BNA Tax Management Portfolios: U.S. Income No. 100. KF6297 .T39 and BNA. Also available on LexisNexis (search for “cite(100)”) and Westlaw.
  • U.S. Tax Overview: Structure of the Federal Tax System of the United States. BNA and Westlaw.
  • “Federal Income Taxation,” chapter 3, in Specialized Legal Research. KF240.S64 1987.
  • Georgetown Law Library, Federal Tax Research Guide.
  • West's Federal Tax Research, 6th ed. KF241.T38R33 2003.
  • Gardner, Tax Research Techniques, 6th ed. KF241.T38G35 2003.
  • Pratt, Kowal & Martin, “The Virtual Tax Library: A Comparison of Five Electronic Tax Research Platforms” (September 28, 2007). Loyola-LA Legal Studies Paper No. 2007-37. Available at SSRN: http://ssrn.com/abstract=1017925.
  • TaxCite: A Federal Tax Citation and Reference Manual. KF245.T39 1995.
  • West's Tax Law Dictionary. KF6287 .W473.

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Secondary Sources

It is always a good idea, when researching an unfamiliar area of law, to start with secondary sources. Secondary sources provide an overview and analysis of the law, as well as citations to primary sources. Starting with secondary sources can save you time and help you identify all the issues. Here are some examples of authoritative secondary sources for federal tax research.

Treatises

The following list is only a small sample of available tax treatises. To find more, search the library catalog, check the directories on Westlaw or LexisNexis, or ask a reference librarian.

  • Federal Estate and Gift Taxation by Stephens, Maxfield, Lind, Calfee, and Smith. Westlaw: WGL-GIFTAX.
  • Federal Income, Gift and Estate Taxation by Rabkin & Johnson. LexisNexis: FEDTAX;FIGETX.
  • Federal Income Taxation of Corporations and Shareholders by Bittker & Eustice. Westlaw: WGL-CORP.
  • Federal Income Taxation of Corporations Filing Consolidated Returns by Dubroff, Blanchard, Broadbent & Duvall. LexisNexis: FEDTAX;CONRET.
  • Federal Income Taxation of Individuals by Bittker, McMahon & Zelenak. Westlaw: WGL-INDV.
  • Federal Income Taxation of S Corporations by Eustice & Kuntz. KF6491 .E84 2001 and Westlaw: WGL-SCORP.
  • Federal Taxation of Income, Estates and Gifts by Bittker & Lokken. Westlaw: WGL-IEG.
  • Federal Taxation of Partnerships & Partners by McKee, Nelson & Whitmire. Westlaw: WGL-PARTNER.
  • IRS Practice and Procedure by Saltzman. Westlaw: WGL-IRSPRAC.
  • International Taxation: U.S. Taxation of Foreign Persons and Foreign Income by Isenbergh. LexisNexis: 2NDARY;INTETX.
  • Law of Tax-Exempt Organizations by Hopkins. KF6449 .H6 2003 and LexisNexis: FEDTAX;LAWTXO.
  • Limited Liability Companies by Bishop & Kleinberger. Westlaw: WGL-LLC.
  • Litigation of Federal Civil Tax Controversies by Kafka & Cavanagh. Westlaw: WGL-LITCIV.
  • Tax Controversies: Audits, Investigations, Trials by Fink. LexisNexis: FEDTAX;TAXFRD.
  • Tax Fraud and Evasion by Comisky, Feld & Harris. KF6334 .C66 and Westlaw: WGL-FRAUD.

Portfolios

Articles

Daily Current Awareness

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Looseleaf and Online Services

The following services integrate primary and secondary sources for tax research.

Primary Sources

In legal research, your goal is to find the Law that applies to your client's situation. Law is found in “primary authorities,” which are issued by the government. All three branches of the U.S. government make tax law, but they also publish other helpful information.

Tax law is code-based, so you should begin your primary-source research with statutes. If you are unfamiliar with an area of law, it is a good idea to begin your research with a secondary source, which will help you find the relevant statutes.

Legislative Branch

Statutes

  • The current Internal Revenue Code can be found at title 26 of the U.S. Code. It is also published in annual Internal Revenue Code volumes (KF6276.526.A19 I57, most recent on Reserve) and is included in most of the services listed above.
  • Tax statutes are originally published as Public Laws. You can find tax-related Public Laws in Statutes at Large and USCCAN. The are also compiled in The Internal Revenue Acts. KF6275.99 U54, current issue on Reserve.

Legislative History

Although legislative history documents are not Law, they can be helpful in determining the purpose of tax statutes. Some legislative history documents can also be used as “substantial authority” to avoid a penalty under I.R.C. § 6662(b)(2). See 26 C.F.R. § 1.6662-4(d)(3)(iii).

For detailed instructions on conducting legislative-history research, see Legislative History: A Research Guide. The following are specialized sources for tax legislative history.

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Executive Branch

Regulations

  • Current Treasury Regulations are codified at title 26 of the Code of Federal Regulations (C.F.R.).
  • Final and proposed Treasury Regulations are originally issued as Treasury Decisions, which include the text of the regulation as well as a preamble that includes background, explanation, and analyses of the regulation. Treasury Decisions are published in the Federal Register, the Internal Revenue Bulletin, and the Cumulative Bulletin.

Other I.R.S. Publications

I.R.S. Publications vary in importance. Those published in the Internal Revenue Bulletin, most importantly Treasury Regulations, Revenue Rulings, and Revenue Procedures, can be cited as authority. The others listed here can be used as “substantial authority” to avoid a penalty under I.R.C. § 6662(b)(2). See 26 C.F.R. § 1.6662-4(d)(3)(iii). See the Sources of Federal Tax Materials chart for information on where to find these primary sources.

  • Revenue Rulings;
  • Revenue Procedures;
  • Private Letter Rulings and Technical Advice Memoranda;
  • Actions on Decisions and General Counsel Memoranda;
  • Internal Revenue Service information or press releases; and notices, announcements and other administrative pronouncements published by the Service in the Internal Revenue Bulletin.

Judicial

  • Tax Court
  • U.S. District Court
  • U.S. Court of Appeals
  • U.S. Supreme Court

Treaties

For more information on treaty research, see the research guide on Treaties and International Agreements and the International Law Portal.

  • U.S.Tax Treaties Reporter includes income and estate tax treaties, official analyses, regulations, CCH explanations, and annotations to administrative rulings and court decisions. CCH Tax Research NetWork under the International Tax and Federal Tax tabs.
  • Rhoades & Langer U.S. International Taxation & Tax Treaties includes U.S. tax treaties and agreements, as well as annotations and analysis. LexisNexis: FEDTAX;INTTXT.
  • Tax Analysts Worldwide Tax Treaties Combined Files includes tax treaties, amending protocols, and similar documents; legislative history of U.S. tax treaties; administrative documents; and treaty news and analysis. LexisNexis: FEDTAX;TAWTT.
  • RIA International Tax Treaties and Explanations includes agreements between the U.S. and other countries relating to tax, with legislative history and editorial analysis. Westlaw: RIA-TREATIES.
  • Federal Taxation - U.S. Treaties and Conventions includes tax treaties between the U.S. and foreign governments beginning with 1844, but no annotations or analysis. Westlaw: FTX-TREATIES.
  • HeinOnline: Treaties and Agreements Library.
  • Federal Tax Coordinator 2d, chapter O. KF6285.T49 and Westlaw: RIA-FTC.
  • The Internal Revenue Service's Tax Information for International Businesses has links to Tax Treaties and Competent Authority Agreements.

Forms

Databases

In addition to the specific databases for individual types of IRS pronouncements and written determinations, LexisNexis and Westlaw have group databases that combine several types of documents. Each service also has some unique databases. Check the online and print directories for more information.

Westlaw

  • IRS Combined Releases: Combines materials from the following databases: IRS Cumulative Bulletins, Written Determinations, and News Releases (FTX-CBWD), IRS Memoranda and Actions on Decisions (FTX-MEMOS), Industry Specialization Program (FTX-ISP), IRS Market Segment Specialization Program (FTX-MSSP), IRS Exemption Rulings (FTX-EXEMPT), IRS Information Letters (FTX-INFO), and IRS Miscellaneous Documents (FTX-IRSMISC).
  • FTX-CBWD: Combines documents from the following databases: IRS Written Determinations (FTX-WD), IRS Cumulative Bulletins (FTX-CB), and IRS News Releases (FTX-NR).
  • FTX-MEMOS: Combines materials from the following databases: IRS General Counsel Memoranda (FTX-GCM), IRS Actions on Decisions (FTX-AOD), IRS Technical Memoranda (FTX-TM), IRS Litigation Bulletins (FTX-LB), and IRS Litigation Guideline Memoranda (FTX-LGM).
  • IRS Written Determinations (Combined Materials): Combines documents from databases containing written determinations issued by the Internal Revenue Service: private letter rulings (FTX-PLR), technical advice memoranda (FTX-TAM), chief counsel advice (FTX-CCA), field service advice (FTX-FSA), litigation bulletins (FTX-LB), litigation guideline memoranda (FTX-LGM), nondocketed service advice reviews (FTX-NSAR), service center advice (FTX-SCA), and information letters (FTX-INFO).

LexisNexis

  • IRS Bulletins, Letter Rulings & Memoranda Decisions, Combined: A group file consisting of the Internal Revenue Bulletin/Cumulative Bulletin, including revenue rulings and procedures (CB), Private Letter Rulings/Technical Advice Memorandums (PLR), General Counsel Memorandums (GCM), Actions on Decisions (AOD), Technical Memorandums (TM), Field Service Advice (FSA), Service Center Advice (SCA), Chief Counsel Advice (CCA), Litigation Guideline Memorandums (LGM), General Litigation Bulletins (GLB), Criminal Tax Bulletins (CTB), Tax Litigation Bulletins (TLB), Chief Counsel Notices (IRSCCN).
  • IRS General Counsel Memos, Actions on Decisions, & Technical Memos: A group file consisting of memos from the IRS including General Counsel Memorandums, Actions on Decisions, Technical Memoranda, Field Service Advice, Service Center Advice, Chief Counsel Advice, Tax Litigation Bulletins, Litigation Guideline Memorandums, Criminal Tax Bulletins, and General Litigation Memorandums.
  • IRS Cumulative Bulletin, IRB, Letter Rulings, & Technical Advice Memos: Combines the Internal Revenue Bulletin/Cumulative Bulletin file (CB) and the Private Letter Ruling/Technical Advice Memorandum file (PLR).

BNA Tax and Accounting Center

The BNA Tax and Accounting Center provides access to primary sources, including: the Internal Revenue Code, Treasury Regulations, IRS Proposed Regulations, and federal tax cases and treaties. Also includes US Income Portfolios; Estate, Gifts & Trusts Portfolios; Foreign Income Portfolios; Daily Tax Report and journal articles. Includes similar resources for State Tax materials.

CCH Tax Research NetWork

The CCH Tax Research NetWork provides access to federal and state tax codes and cases. Includes Letter Rulings, IRS Positions (including TAMs and FSAs) and IRS Publications. Contains the Standard Federal Income Tax Reporter and the Tax Treaties Reporter.

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Websites

Tax Analysts http://www.taxanalysts.com/.

Essential Links to Taxes http://www.el.com/elinks/taxes/.

American Institute of Certified Public Accountants Tax Center http://www.aicpa.org/members/div/tax/index.htm.

ABA Section of Taxation http://www.abanet.org/tax/home.html.

Internal Revenue Service: http://www.irs.gov/index.html. Downloadable tax forms and publications, news releases, and regulations, including:

TaxLinks, http://www.taxlinks.com/. Contains a searchable database of revenue rulings, from 1954 to date.

Tax and Accounting Sites Directory, Federal Tax Law, http://www.taxsites.com/federal.html.

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By Alison Ewing and Penny Mattson. Adapted from a guide by Cheryl Nyberg, Gallagher Law Library, University of Washington. Updated 9/08.
Friendly URL: http://www.law.asu.edu/taxresearch.