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Tax Law

An Overview On the Joys of Federal Taxation

Cases

Westlaw, Lexis, and Bloomberg have separate databases for just tax law. 

Westlaw's Tax Page

Lexis' Tax Page

Bloomberg's Tax Page

 

Those three major publishers also have Tax Court opinions, but their coverage can be spotty for the unpublished/memoranda TC decisions.

 

You can also find Tax Court decisions on the Tax Court's website:  ustaxcourt.gov

 

A refresher from the Main Sources of Tax Law page.  Some big sources of tax jurisprudence are:

  • United States Supreme Court
  • Federal appellate courts (aka, the Circuit Courts)
  • US federal district courts
  • Tax Court.  They issue three types of opinion:
    • Regular/Formal Opinions.  Also called TC Opinions or Division Opinions.  This is the kind of judicial opinion we're used to.  Published in the Tax Court Reports, they are binding, precedential, and appealable. 
    • Memorandum (TC Memos or Memo Opinions).  Unpublished, but are still cited.
    • Summary decisions.  Kind of like the 'small claims court' of tax law.  Involves controversies below $50,000.  Not precedential.

 

Abbreviations

AFTR:  American Federal Tax Reports.  They're published by RIA.

BTA Mem. Dec. OR BTAM:  Board of Tax Appeals Memorandum Decisions

TC:  Tax Court

TCM:  Tax Court Memorandum Decisions

TCR:  Tax Court Reporter.  They're published by CCH or RIA.

USTC:  United States Tax Cases

Special Citation Rules

 

Bluebook

  • Tax Court:  BT2.1 (p. 46 in the 21st ed.)
  • Board of Tax Appeals: T1  (particularly p. 237 in the 21st ed.)

 

ALWD

  • Tax Court: 6(B) and 6(B)(1) (page 506-508 in the 7th ed.)

Statutes aka IRC aka Tax Code

The Tax Code/Internal Revenue Code (IRC) is codified in Title 26 of the USC.

 

Westlaw's Tax Page

Lexis' Tax Page

Bloomberg's Tax Page

 

The IRS's own handy page is here.

 

Abbreviations

 

IRC or I.R.C.: Internal Revenue Code aka Tax Code

USC or U.S.C.: United States Code

Prior Versions

There are prior versions of the IRC, namely in 1938, 1954, and 1986.  You'll see them referenced as 'IRC of 1954,' for example.  If you just see IRC listed, assume it's the current version.

Special Citation Rules

 

Bluebook

  • Rule 12.9.1, Internal Revenue Code
  • For citation forms in court documents and legal memoranda, see Bluepages B12.1.4.