Researching Federal Income Tax Law.pdf - University of Houston Law Center O’Quinn Law Library Researching Federal Income Tax Law Introduction to the

Researching Federal Income Tax Law.pdf - University of...

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University of Houston Law Center O’Quinn Law Library Researching Federal Income Tax Law _____________________________________________________________ Introduction to the Research Guide Researching federal income tax law involves a variety of sources and there are several approaches that can be used. Legal Research by tax practitioners should involve becoming familiar with the Internal Revenue Code or at least comfortable finding the relevant code sections. After finding the appropriate code section it is important to find the corresponding treasury regulation for further guidance. Case law can interpret difficult to understand code sections. Administrative decisions can also be helpful but vary with respect to authority depending on the type of document. Documents that are intended for release to the public such as Revenue Rulings or Revenue Procedures are usually binding whereas documents that are released because of the Freedom of Information Act (FOIA) are non authoritative. ___________________________________________________________ Primary Sources A. Internal Revenue Code The Internal Revenue Code is a compilation of tax statutes arranged by subject and is located under title 26 of the United States Code (U.S.C.). The Code is the foundation of all tax law and is the most authoritative source. The code is not very popular given that it is very difficult to interpret and use. United States Code (U.S.C.) Title 26 (KF62.A2 Federal Collection) United States Code Annotated (U.S.C.A.) Title 26 (KF62.U5 Federal Collection) United States Code Service (U.S.C.S.) Title 26 (KF62.U6 Federal Collection) U.S.C.C.A.N. Internal Revenue Code (KF6276.S26.A19I57) B. Treasury Regulations Treasury Regulations are designed to interpret the internal revenue code. They are issued by the Department of Treasury with the intent of providing guidance to the code. Final Treasury Regulations are codified in the Code of Federal Regulations and announced in the Federal Register as Treasury Decisions. Treasury Decisions are also announced in the Internal Revenue Bulletin/Cumulative Bulletin. 1. There are three types of regulations .
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Proposed: Treasury Regulations typically go through a minimum 30 day notice and comment period. During this period professional organizations including the American Institute of Certified Public Accountants (AICPA) and the American Bar Association (ABA) can review the proposed regulations and make comments and suggestions for changes. Proposed regulations are not considered to be binding until they are finalized. Final: Final regulations are authoritative as long as they are “reasonable and consistent interpretations” of the code. Once final regulations are issued they are announced in the Federal Register and codified in the Code of Federal Regulations (CFR). Temporary: Temporary Regulations are regulations that are issued for a maximum period of three years. During this three year period the regulations are as authoritative as the final regulations.
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  • Spring '14
  • JeffreyJ.Bryant

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