General+Tax+Research+Materials

Internal Revenue Code (IRC) Structure: Title 26 of the USC but never cited this way. Divided into subtitles/chapters and further into subchapters. KNOW the chapters/subchapters. Can be helpful when starting research.

Administrative Agency: the Treasury Department interprets the IRC and promulgates regulations or TREASURY REGULATIONS.
 * 1) Final regulations are called **TREASURY DECISIONS** (TD) and cited in Federal Register and Title 26 CFR and INTERNAL REVENUE BULLETIN.
 * 2) **REVENUE RULINGS**: issued as a result of specific rulings to taxpayers (private letter rulings PLR), technical advice (technical advice memorandum TAM) to District offices. Issued in the INTERNAL REVENUE BULLETIN.
 * 3) **REVENUE PROCEDURES**: official statement of procedure or information. Less binding than the aforementioned. Issued in INTERNAL REVENUE BULLETIN.
 * 4) **PRIVATE LETTER RULINGS** (PLR or LTR): issued by the IRS in response to individual taxpayer inquiries. NOT BINDING.
 * 5) **TECHNICAL ADVICE MEMORANDUM** (TAM): issued by the IRS in response to a particular transaction. NOT BINDING.
 * 6) **GENERAL COUNSEL MEMORANDUM** (GCM): issued to provide explantation as a result of a revenue ruling.
 * 7) **ACTION ON DECISION**: internal memo from IRS stating reasons why IRS deciding to follow a holding of a particular court. Usually AODs are accompanied by an **ACQUIESCENCE.**

Court Structure:

Courts of Original Jurisdiction:
 * US Tax Court:** taxpayer does not pay tax deficiency. Decisions in US Tax Court Reports


 * Federal District Court:** taxpayer pays tax deficiency. Only court can request a jury trial. Decisions in Fed Supp, CCH's United States Tax Cases (USTC) or RIA's American Federal Tax Reports (AFTR)


 * US Court of Federal Claims:** taxpayer pays tax deficiency. Decisions in US Court of Federal Claims reporter (Fed. Cl.), CCH's United States Tax Cases (USTC) or RIA's American Federal Tax Reports (AFTR).

Secondary Sources:
 * Standard Federal Tax Reporter**: CCH


 * United States Tax Reporter**: RIA.