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                                           FEDERAL TAXATION
                                                         Research Guide



                                            INTRODUCTION


The statutes that regulate taxation are often referred to as the Internal Revenue Code (IRC or “the Code”)
and can be found in the United States Code, United States Code Annotated, or United States Code Service.
The statutes are also printed in two major loose-leaf services: CCH’s Standard Federal Tax Reporter and
RIA’s United States Tax Reporter. There are three major revisions to the code: 1939, 1954 and 1986.

The Internal Revenue Service makes rules and regulations to implement the statutes. Taxation regulations
are codified in Title 26 of the Code of Federal Regulations (CFR.). Final and temporary tax regulations are
issued as Treasury Decisions (TDs), and published in the Cumulative Bulletin (CB). The IRS also publishes
proposed, temporary and final regulations in the Federal Register. CCH’s Standard Federal Tax Reporter
and RIA’s United States Tax Reporter include regulations, organized by Code section.

Note: Tax regulation section numbers start with a numerical designation of the type of tax issue involved.
Common classifications are: 1. Income Tax; 20. Estate Tax; 25. Gift Tax; 31. Employment Tax; 301
Procedural Matters. The numbers after the decimal start with the number of the Code section under which
they are promulgated. For example, 26 C.F.R. 1.167(a) -1 is the first regulation under the income tax code
section 167(a).

This research guide focuses on federal taxation materials available at the Chastek Law Library. Most print
taxation materials are located in the Kelley Room.



                                  ADMINISTRATIVE MATERIALS
                  (see chart at end of guide to find where these documents are published)

1. Official documents:

    The following official documents are all published in the Internal Revenue Bulletin (IRB), KF6276.99
    .A3, Kelley Room. This weekly publication is cumulated twice yearly in the Cumulative Bulletin (CB),
    KF6276.99 .A3, Kelley Room.

    •   Treasury Decisions. Final and temporary tax regulations. Authoritative.

    •   Proposed regulations. Not authoritative.
October 2005                                         1
    •   Revenue Rulings. Ruling applying the law to particular facts presented by a taxpayer. Authoritative
        for same factual circumstances, unless officially revoked.

    •   Revenue Procedures. Statements of I.R.S. practices and procedures. Authoritative.

    •   Other notices (for example, meeting notices).

2. Other documents:
    •   Private Letter Rulings (PLR's or LTR's). Written by the IRS National Office in response to a
        taxpayer. They interpret specific facts. Letter rulings are assigned a file number (e.g., 8102077) in
        which the first two digits show the year of issuance, the next digits show the week of issuance, and
        the remaining digits show the order of issuance in that particular week. Not authoritative.

    •   Technical Advice Memoranda (TAM's). Contain advice from the IRS National Office to an IRS
        District Director Appeals Officer (auditor). Not authoritative.

    •   General Counsel Memoranda (GCM). Issued by the IRS Office of Chief Counsel to explain
        reasoning and authority underlying revenue rulings, letter rulings, and technical advice memoranda.
        Not authoritative.

    •   Action on Decision (AOD). Memo published by IRS counsel to indicate whether Commissioner
        should appeal, acquiesce in or not acquiesce in a Tax Court decision.

    •   Transmittal or Technical Memoranda. Background information prepared to accompany published
        regulations (in addition to the preamble introducing the regulation).

    •   Operating policies. Internal IRS procedures.

3. Court Opinions

Judicial Decisions. The United States Tax Court issues two kinds of decisions: Regular decisions and
Memo decisions. The Regular Opinions are published in the United States Tax Court Reports (official
publication), KF6324 .A5, Kelley Room. There is no official reporter for Court Memo Decisions.
All Tax Court decisions, Regular and Memo, are published unofficially in the CCH Tax Court Reporter,
KF6280 .A253, Kelley Room (older decisions are moved to transfer binders). Memorandum decisions are
also published in Tax Court Memorandum Decisions, KF6281 .A25, Kelley Room.



                                   LOOSELEAFS AND REPORTERS

Standard Federal Tax Reporter, CCH, current edition, KF6365 .C6, Kelley Room. A good starting point
for most federal tax research, this set is arranged by code section. Includes statutes, regulations, notes of
court and administrative decisions, other administrative documents, some legislative history, and
commentary. Finding aids include lists of Revenue Rulings, cases, Treasury Decisions, Private Letter
Rulings, etc., linked to the relevant paragraphs in the Compilation volumes. These finding aids appear in the
Citator Volume (M-Z).


October 2005                                            2
United States Tax Reporter, RIA, c1990 – present, electronic access through Checkpoint and Westlaw.
Another good starting point for most federal tax research this set is also arranged by code section. Includes
statutes, regulations, notes of court and administrative decisions, other administrative documents, some
legislative history, and commentary. In Volume 2, the USTR has lists of Revenue Rulings, cases, Treasury
Decisions, Private Letter Rulings, etc., linked to the relevant paragraphs within the set.

Mertens Law of Federal Income Taxation, 1955 – present, KF6369 .M43, Kelley Room, electronic access
through Westlaw. Arranged by topic this set includes code sections, final regulations, Revenue Rulings, and
commentary. Supplements are located at the front of each volume. This source provides very
comprehensive commentary and is considered the best source for Regulation Preambles, which are the
explanatory text that accompanies Proposed and Final Regulations justifying the promulgation of the
Regulation.

Internal Revenue Manual, CCH, KF6314. A6C6 (Audit volumes) and KF6301 .A6 C6 (Administrative
volumes), Kelley Room, electronic access through Westlaw and Lexis. The Internal Revenue Manual
consists of IRS instructions to its employees. The Manual is divided into Audit and Administration
volumes.

Federal Tax Coordinator 2d, RIA, 1977 – present, electronic access through Checkpoint and Westlaw.
Includes code and regulations, with analysis. Covers income, FICA, FUTA, estate, gift and excise taxes.
Logically organized and easy to use even by the non-tax specialist, it provides in-depth analysis of all tax
areas with practical advise, cautions and recommendations.

Tax Management Portfolios. BNA, 1971 - present, KF6289 .A1 T35, Kelley Room. Each portfolio covers
a separate topic in the areas of income taxation, estate and gift taxation and foreign income. An excellent
starting point. If a portfolio is available for your topic, it will provide an overview of the law and citations
to primary materials. See Code Section Index to find portfolios by Code section.

Federal Estate and Gift Tax Reporter, CCH, 1983 – present, KF6571 .A8 C65 1983, Kelley Room.
Arranged like CCH’s Standard Federal Tax Reporter; i.e., by code section.

Federal Excise Tax Reporter: Code, Regulations, Rulings, Decisions, CCH, 1963 - present, KF6600 .A6
C64, Kelley Room. Arranged like CCH’s Standard Federal Tax Reporter; i.e., by code section.

IRS Letter Rulings Reporter, CCH, 1977 – present, KF6301 .A6 C5, Kelley Room. Includes Topical index
and Code Finding List.



                                      SUBSCRIPTION DATABASES

The following databases provide comprehensive coverage of state and federal tax law, e.g. statutes, codes,
rules, regulations, court opinions, administrative decisions and IRS materials. Some tax law periodicals and
other publications are also provided. Databases can be accessed through the Chastek Library’s homepage,
Legal Indexes and Databases link. Note: Checkpoint is available to all users on the Gonzaga University
campus. Remote access is available only to Gonzaga University users with current network access.
LexisNexis and Westlaw databases are available only to School of Law students and faculty.


October 2005                                           3
(Note: 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.)

    •   RIA Checkpoint: Comprehensive coverage of all aspects of international, federal, state and local
        taxation law. A training guide is available: Getting the Most out of Your Tax Research with
        Checkpoint, KF241 .T38 G47 2004, Reference Desk Collection. See the comprehensive RIA
        Checkpoint User Guide for additional information:
        http://ria.thomson.com/main/support/ckptqrc.pdf.

    •   LexisNexis: Gonzaga University School of Law student and faculty access only, registration and
        password required. Research guide available at:
        http://www.lexisnexis.com/lawschool/learning/reference/pdf/2005/taxlaw5.pdf.

        FEDTAX:RELS, Federal Tax Library, IRS Releases Combined file: 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).

        FEDTAX:MEMOS, Federal Tax Library, General Counsel Memos, Actions on Decisions and
        Technical Memos Combined file: A group file consisting of memos from the IRS including
        General Counsel Memorandas, 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.

        FEDTAX:CBPLR, Federal Tax Library, Private Letter Rulings and Cumulative Bulletin
        Combined file: Combines the Internal Revenue Bulletin/Cumulative Bulletin file (CB) and the
        Private Letter Ruling/Technical Advice Memorandum file (PLR).

    •   Westlaw: Gonzaga University School of Law student and faculty access only, registration and
        password required. Research guide available at:
        http://west.thomson.com/westlaw/guides/practice/tax.asp.

        FTX-RELS, Federal Taxation, IRS combined releases database: 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, Federal Taxation combination database: Combines documents from the following
        databases: IRS Written Determinations (FTX-WD), IRS Cumulative Bulletins (FTX-CB), and IRS
        News Releases (FTX-NR).

        FTX-MEMOS, Federal Taxation combination database: 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
October 2005                                         4
        Guideline Memoranda (FTX-LGM).

        FTX-WD, IRS Written Determinations combination database: 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 e memoranda
        (FTX-LGM), nondocketed service advice reviews (FTX-NSAR), service center advice (FTX-SCA),
        and information letters (FTX-INFO).

        FTX-BLUEBOOKS, Joint Committee on Taxation's General Explanation of Tax Legislation
        (commonly called the Blue Books). Issues for 1976, 1981, 1982, 1986, 1991, 1993, 1996, 1997,
        1998, and all editions from 2001 to the present.



                                          TEXTS & TREATISES

Federal Taxation of Income, Estates, and Gifts, Boris I. Bittker and Lawrence Lokken, KF6335 .A7 B57
1999, Kelley Room, electronic access through Checkpoint and Westlaw. Arranged by topic. Bittker is a
highly respected tax scholar and this work is one of the leading treatises on taxation. Six volumes of this
treatise are devoted to legislative history.

IRS Practice and Procedure Deskbook, Ira L. Shafiroff, KF6301 .S52 1998 – present, Kelley Room,
electronic access through Westlaw. Covers IRS procedures from drafting a ruling request to preparing for
an appeals conference, from handling a criminal investigation to dealing with a revenue officer in a tax
collection case.

Federal Income Taxation of Individuals, Boris I. Bittker and Martin J. McMahon, Jr., KF6369 .B57 2002,
Kelley Room, electronic access through Westlaw. Organized by topic, but contains tables of IRC sections,
Treasury regulations, revenue rulings, revenue procedures, and other IRS releases.

RIA Federal Tax Handbook 2001, KF6289 .R523, Kelley Room, electronic access through Checkpoint.
Designed as a quick reference tool; not as comprehensive as the big looseleaf services. Covers individual
and corporate taxation, pension plans, employee benefits, deductions, passive losses, estate and gift taxes,
etc.

Federal Income Taxation: A Law Student's Guide to the Leading Cases and Concepts, Marvin A.
Chirelstein, KF6369 .C43 2002, Third Floor. This relatively small book has helped many tax-impaired
students survive tax law classes.

Federal Income Taxation of Individuals with Diagrams for Easy Understanding of the Leading Cases
and Concepts, Daniel Q. Posin, KF6369 .P67 2000, Kelley Room.

Federal Income Taxation, Michael D. Rose and John C. Chommie, KF6369 .R67 1988, Kelley Room.




October 2005                                          5
                                COMPILED LEGISLATIVE HISTORIES

Internal Revenue Acts of the United States, 1909-1950: Legislative Histories, Laws, and Administrative
Documents, Bernard D. Reams, et al., KF6275.8 1979, Third Floor.

Internal Revenue Acts of the United States, 1950-1951: Legislative Histories, Laws, and Administrative
Documents, edited by Bernard D. Reams, KF6275.8 1982a, Third Floor.

Internal Revenue Acts of the United States: Revenue Acts of 1953-1972 with Legislative Histories, Laws
and Congressional Documents, compiled by Bernard D. Reams, KF6275.8 1985, Second Floor Microfiche
Collection.

Seidman's Legislative History of Federal Income Tax Laws, 1938-1861, Jacob Stewart Seidman,
KF6356.52 .A16 S4 1953, Rare Book Room Collection.

Legislative History of Federal Income and Excess Profits Tax Laws, 1953-1939, Jacob Stewart
Seidman, KF6356.53 .A15 S4, Rare Book Room Collection.

The Internal Revenue Code of 1954: Bill H.R. 8300, an Act to Revise the Internal Revenue Laws: The
Bill in its Various Forms as Considered by the 83rd Congress, 2d Session, compiled by Bernard D.
Reams, KF6276.526 .A15 1993, Third Floor.

Tax Reform 1984: A Legislative History of the Tax Reform Act of 1984: The Law, Reports, Hearings,
Debates, and Related Documents, Bernard D. Reams, KF6276.557 .A15 1985B, Third Floor Microfiche
Collection.

Tax Reform 1986: A Legislative History of the Tax Reform Act of 1986: The Law, Reports, Hearings,
Debates, and Related Documents, Bernard D. Reams and Margaret H. McDermott, KF6276.558 .A15
1987, Third Floor.

Tax Management Primary Sources, BNA, 1970 – present, KF6365 .B87, Kelley Room.

1939 Code history is also published in the Cumulative Bulletin, 1939-2, pt. I, KF6276.99 .A3, Kelley
Room.

For legislative history research consult the Congressional, LexisNexis, and Westlaw databases.



                    NEWSLETTERS, JOURNALS AND PERIODICAL INDEXES

Note: To locate print and electronic copies of the journals listed below search for individual titles though
Chastek Library’s E-Journal Portal, http://dd8qg8az7w.search.serialssolutions.com.

Newletters

The Washington Tax Review

Tax Notes (comprehensive and timely coverage of current IRS actions, published weekly.)



October 2005                                           6
Journals (selected)

Akron Tax Journal

American Journal of Tax Association of Tax Bulletin

Boston University Journal of Tax Law

Florida Tax Review

The Journal of Taxation

Practical Tax Lawyer

Tax Law Review (NYU)

Taxes: The Tax Magazine

The Tax Lawyer: Bulletin of the Section of Taxation, American Bar Association

Virginia Tax Review

Periodical Indexes

Federal Tax Articles (CCH) - Descriptions of federal tax articles, comments and notes published in legal,
accounting, tax and other periodicals and professional journals. KF6335 .A6 C66, Kelley Room.

LegalTrac – available through the library’s website, Legal Indexes and Databases link LegalTrac is the
electronic equivalent to the Current Law Index. Use this database to find articles in all major law reviews,
law journals, specialty law and bar association journals, and legal newspapers. This database covers the
materials published from 1980 forward. Search LegalTrac by keyword, subject, author, or title.

Checkpoint, Westlaw and LexisNexis also provide access to numerous tax-related journals and newsletters.



                                                 WEBSITES

Below is short list of free web sites that may be helpful for researching tax-related issues.

    •   State Tax Agencies & Tax Forms, www.taxadmin.org/fta/link, Links to agency home pages, forms
        and publications compiled by the Federation of Tax Administrators.

    •   Tax World, www.taxworld.org, International, federal, state & local tax-related information and
        links.

    •   ABA Tax Section, www.abanet.org/tax, American Bar Association’s website.

    •   Federation of Tax Administrators, www.taxadmin.org, includes Federal Legislative & IRS Links
        (www.taxadmin.org/fta/link/fed_link.html) and links to Private Sector and Policy Oriented Tax
        Groups (www.taxadmin.org/fta/link/private.html).

October 2005                                           7
    •   Tax & Accounting Sites Directory, www.taxsites.com, comprehensive index of international,
        federal and state web sites.

    •   Tax Prophet, www.taxprophet.com, contains a variety of tax publications, coverage of recent hot
        topics, and links to tax sites.

    •   The Internal Revenue Service, http://www.irs.ustreas.gov/index.html, official IRS site with for tax
        information for individuals, businesses, charities & non-profits, government entities, tax
        professionals, retirement plans community, and tax exempt bond community.

    •   Tax Links, www.taxlinks.com, contains a searchable database of revenue rulings from 1954 to date.



                                              TAX FORMS

Reproducible Copies of Federal Tax Forms and Instructions, KF 6301 .A47 (multiple locations – check
the public catalog).

Current and previous federal tax forms and publications are available online at
http://www.irs.ustreas.gov/formspubs/index.html

Current Washington tax forms are available online at http://dor.wa.gov/content/forms/excise/default.aspx

                                          RESEARCH GUIDES

William A. Raabe, West's Federal Tax Research, 5th ed., KF 241 .T38 W47, Greenan Reading Room.

Gail Levin Richmond, Federal Tax Research: Guide to Materials and Techniques, 6th ed., KF 241 .T38
R5 2002, Greenan Reading Room.

Kathryn Fitzhugh's "Federal Income Taxation," Chapter 3 of Leah Chanin's Specialized Legal
Research, KF 240 .S69 1987, Reference Desk Collection.

Links to other Research Guides which may be helpful:

University of Minnesota: www.law.umn.edu/library/tools/pathfinders/ResearchFedTaxLaw.html
Gonzaga’s guide was modified with permission from this guide prepared by Mary Rumsey & Suzanne
Thorpe.
Georgetown (good detailed guides):
http://www.ll.georgetown.edu/guides/federal_tax.cfm federal tax research guide
http://www.ll.georgetown.edu/guides/fedtax_chart.cfm federal tax reference chart
http://www.ll.georgetown.edu/guides/state_local_tax.cfm state & local tax research guide

NYU (a basic guide):
http://www.law.nyu.edu/library/taxres1.html federal tax research for beginners

Golden Gate:
http://www.ggu.edu/lawlibrary/studentstudyaids/attachment/gde4E.pdf federal taxation guide


October 2005                                         8
                         MAJOR PUBLICATIONS CONTAINING PRIMARY TAX AUTHORITIES
                                 (available at Gonzaga University Chastek Law Library)

                                                           Authorities
   Sources
                                                                                            Fed.
                 Legis.                           Prop. Rev. Rev.                     Oper.
                        Statutes Code Treaties TD                  LTR TAM GCM AOD TM        Ct. TC TCM
                 Hist.                            Regs. Proc. Rul.                     Pol.
                                                                                            Cases
 Internal Rev.
                  X        X           X     X   X    X     X                                X
    Bulletin
 Cumulative
                  X        X           X     X   X    X     X                                X
  Bulletin
 Tax Ct. Rptr.                                                                                   X
Std. Fed. Tax
                  X              X           X   X    X     X     X                              X   X
  Reporter
U.S. Tax Rptr.    X              X           X   X    X     X     X                              X   X
  Fed. Tax
                  X              X     X     X   X    X     X     X
Coordinator 2d
 Tax Mgmt.
                  X                    X
 Portfolios
 Tax Mgmt
                  X        X
Prim. Sources
 Internal Rev.
                                                                                         X
    Manual
  IRS Letter
                                                                  X      X   X   X   X
   Rulings
   Mertens        X              X           X        X     X
 Internal Rev.
                           X
     Acts
 Internal Rev.
                                 X
     Code
   Seidman        X        X
    Reams         X        X
Am. Fed. Tax
                                                                                             X
 Reporter
Tax Ct. Rprtr.                                                                                   X
Tax Ct. Rpts.                                                                                    X
Tax Ct. Memo.
                                                                                                     X
  Decisions
 T.C. Memo.
                                                                                                     X
  Decisions
U.S. Tax Cases                                                                               X
    LEXIS         X        X     X     X     X   X    X     X     X      X   X   X   X   X   X   X   X
 WESTLAW          X        X     X     X     X   X    X     X     X      X   X   X   X   X   X   X   X
          October 2005                                 9
     RIA
                 X      X   X   X   X   X   X    X   X   X   X   X   X   X   X   X   X
Checkpoint.com




         October 2005                       10

				
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