# AN INTRODUCTION TO TAX-RELATED LEGAL RESEARCH

## 

## 

### ***Professor Michele LaForest Halloran***

### ***Professor Andrew S. Campbell***

***Michigan State University College of Law***

***2007 Grantee LITC Conference***

***December 2007***

[I. Introduction]{.smallcaps}

A.  **[P]{.smallcaps}urpose and Scope of this Guide**

This guide is designed to help you to do federal tax research using
readily-available texts and various on-line resources. Major sources are
briefly described. This guide is designed primarily for those who have
little or no experience in performing federal tax research; it is not a
comprehensive treatise on the subject, but instead is a concise summary
of the more important current sources of information that are available.
Call numbers for selected titles discussed in this guide are based on
the Library of Congress classification system and are provided in
brackets, e.g., **\[KF 240 .J32 1994\].**

##### II. Preliminary Considerations

###### **A. Federal Tax Materials** 

Many legal researchers are intimidated by tax research, thinking that it
is more complex and radically different from the usual process of legal
research. However, many of the same tools used in general legal research
are also applied in performing tax research. Depending on your
familiarity with tax law, you may wish to begin researching with
secondary sources or with the primary law itself. Federal tax materials
include the United States Constitution, statutes, case law,
administrative rulings, legislative history material, and secondary
sources.

###### **Purposes of Federal Tax Materials** 

Taxation issues arise in a variety of contexts, and are not the sole
domain of tax attorneys. An advisor may wish to discover the tax
implications of a judgment or settlement offer, a divorce agreement, or
a business transaction, and this will necessitate delving into fairly
sophisticated tax research techniques. You may simply want to know what
circumstances, if any, give rise to adoption of a particular tax
statute. Thus, many individuals who do not deal with taxation issues on
a regular basis still may need to perform some form of tax research.
This guide is designed to assist individuals who are fairly unfamiliar
with tax resources to conduct basic tax research, but also is helpful as
an extensive compilation of resources for those with more definitive
expertise.

##### III. The Process of Federal Tax Research 

###### **Federal Tax Research -- The Computer and Beyond** 

The process of federal tax research, and legal research in general, is
changing rapidly, as more and more resources become available over the
Internet. Several major websites, available without cost to the public,
provide detailed materials that can be very helpful in doing federal tax
research. Among these are:

http://www.irs.gov

> [http://www.taxsites.com](http://www.taxsites.com/) (includes a
> listing of topics, forms, updates, links, and
>
> policy information in tax/accounting/payroll settings)
>
> <http://www.findlaw.com/01topics/35tax/index.html> (has public and
> professional
>
> sites)
>
> <http://www.law.cornell.edu/topics/income_tax.html> (the Legal
> Information
>
> Institute)

In addition to these free public resources, both Lexis and Westlaw
provide access to many specialized tax databases. The **FEDTAX** library
contains tax information on Lexis, and the **FTX** database contains the
federal tax information on Westlaw. Consult the Lexis Directory of
Online Services or the Westlaw Database Directory for specific tax
databases.

###### **B. Published Federal Tax Research Guides**

Various textbooks, journal articles, and other materials offer
assistance and instruction in performing federal tax research. The
following materials, some of which were consulted in preparation of
these materials, are a good place to start when researching tax law;
most include annotated bibliographies:

Leah F. Chanin, [Specialized Legal Research]{.underline}, ch. 3 (updated
annually).

> **\[KF 240 .S64 1987\]**

Robert L. Gardner, [Tax Research Techniques]{.underline} (5^th^ ed. Rev.
2000) (Note: There currently is a 6^th^ edition of this text.)

**\[KF 241 .T38 G35 2000\]**

J. Myron Jacobstein et al., [Fundamentals of Legal
Research]{.underline}, ch. 24 (8^th^ ed. 2002).

**\[KF 240 .J32 2002\]**

Patricia T. Morgan, [Tax Procedure and Tax Fraud in a
Nutshell.]{.underline} (2^nd^ ed. 2006).

**\[KF 6324 .Z9 M67 2006\]**

William A. Raabe, [West\'s Federal Tax Research]{.underline} (6th ed.
2003).

**\[KF 241 .T38 R33 2003\]**

Gail Levin Richmond, [Federal Tax Research]{.underline} (6th ed. 2003).

**\[KF 241 .T38 R33 2003\]**

University of San Diego, Pardee Legal Research Center, Guide Series,
[Federal Tax Research: Basic Sources.]{.underline}
<http://www.sandiego.edu/lrc/about/pdf/GS-11.pdf>

B.  **Fundamental Tax Research Principles**

> Accurate and active performance of legal research is "sleuthing" at
> its best.

Rarely will an investigation into one issue or case permit you to walk
away with a definitive answer to your question. Most frequently, an
examination of one case, its explanation, and reference to other cases
will launch you into another search or area of inquiry -- it may be some
time before you have gathered sufficient information about your issue,
and how courts and commentators have viewed it, before you can make a
decision about your situation. [Sheer determination differentiates
between those who unearth the better authority -- and thus, the better
argument -- and those who are left scraping the surface.]{.underline}

*[What are the key elements of excellent tax-related legal
research?]{.underline}*

-   [A solid understanding of the totality of the facts confronting your
    client's tax problem.]{.underline} For example, it's not enough to
    simply know that your client has a child tax credit problem for tax
    year 2004 -- at the outset, you must conduct a careful interview to
    ascertain all pertinent facts relative to the client's credit claim.
    Remember -- it is not likely that your client will offer up all key
    facts; the interview must uncover relevant information. If you are
    not knowledgeable of your client's factual scenario, you will be
    wholly unable to determine whether the fruits of your expert tax
    research are applicable to your client's claim. *E.g.,* you have
    uncovered a recent Tax Court case with an opinion favorable to a
    generalized version of your client's circumstance -- without a
    detailed understanding of the client's specific situation, you will
    be unable to determine whether or not the Tax Court case is
    relevant. After the interview, and as soon as possible, write up the
    facts -- this narrative will assist you in comparing your client's
    situation to other fact patterns you come across in your research,
    and will pave the way for identification of "searchable" terms for
    electronic-based research.

-   [Question identification.]{.underline} It often is a challenge in
    tax matters to sort through what the real issues are in the case. As
    you read through reported tax cases, you will recognize that cases,
    that may seem fairly identical from a factual standpoint, may have
    yielded different results because of the manner in which the issues
    were constructed and presented to the court. And, as your
    consideration of your client's matter progresses, you may find that
    you need to reformulate the question. Finally, in formulating the
    question, be sure to allow room for creative thinking -- while
    experience may enable you to easily state the question, examine it
    for the potential that there are facets to the issue you have not
    considered.

-   [Reduction of facts to "searchable" terms.]{.underline} This is
    particularly significant if you plan to use an electronic database
    to perform your research. For example, if you are confronted with
    the question of whether a nonresident alien student from Germany is
    required to pay back his previously-taken treaty benefits if he or
    she stays in the United States beyond the permitted time, you might
    jot down key search terms that will yield a solid return of data
    from your electronic search. [It's a "garbage in/garbage out"
    scenario -- your ability to retrieve good potential research is only
    as effective as your ability to properly characterize search
    terms.]{.underline} Note that this is a talent that you achieve over
    time and "by dint of doing" -- your tenacity will definitely pay
    off!

> Here are a few examples: Someone who wishes to research cases/matters
> involving a taxpayer's eligibility for an earned income credit for a
> foster child might style a LEXIS search as follows: earned income
> credit w/29 eligib! w/50 foster child. This search would pull up all
> materials in which the phrase "earned income credit" appears within 20
> words of words like "eligible" or "eligibility" (we use the
> exclamation point after eligib! to include multiple words in our
> search) and words like eligible or eligibility are within 50 words of
> "foster child." A recent LEXIS search using this search string
> produced thirty-five "hits," including an IRS notice, a Code section,
> many Tax Court cases, Congressional committee publications and
> conference agreements.
>
> Someone who wants to research Tax Court jurisdiction relative to
> collection due process hearings might style a LEXIS search as
> collection due process hearing w/10 Tax Court 2/5 jurisdiction. A
> recent LEXIS search using this search string produced thirty-four
> "hits," including US District Court cases, a chief counsel memo,
> federal appeals court cases, Congressional committee reports, and a
> chapter of the Internal Revenue Manual.

##### IV. Federal Tax Research Materials

**A. The Internal Revenue Code**

Tax law is enacted in the same manner any other federal law. The
Internal Revenue Code comprises Title 26 of the United States Code, and
is divided into subtitles, chapters within the subtitles, and
subchapters within the chapters. For example, Chapter A deals with
income taxes, and is further divided into chapters and subchapters, of
which Subchapter K deals with partners and partnerships. Various sources
contain the Internal Revenue Code.

**UNANNOTATED CODE:**

-   Internal Revenue Code: including all 2005 amendments

**\[KF 6335 .I547 2006\]**

-   U.S. Tax Code On-Line

**\< http://www.fourmilab.ch/ustax/ustax.html \>**

-   U.S. Code - Legal Information Institute, Cornell Law School

**\< http://www4.law.cornell.edu/uscode/26/\>**

-   Also available through CCH Tax Research NetWork

**ANNOTATED CODE:**

-   United States Code Annotated, Title 26

**\[KF 62 1927 .W45\]**

-   United States Code Service, Title 26

**\[KF 62 1972 .L38\]**

-   CCH Standard Federal Tax Reporter (Note: This is known as an
    "annotated service," and includes a multitude of information
    critical to tax researchers, including the Code, legislative history
    references, explanations, and annotations relating to the particular
    Code section.) **\[KF 6285 .C6\]**

```{=html}
<!-- -->
```
-   Also available through CCH Tax Research NetWork

```{=html}
<!-- -->
```
-   Federal Tax Coordinator 2d RIA (A topical service available both
    electronically and in print with detailed tax law explanations.)
    **\[KF 6285 .T3\]**

-   Lexis - Library: FEDTAX; File: CODE

-   Westlaw - Identifier: FTX-USCA

**RECENT LEGISLATION**

-   CCH Standard Federal Tax Reporter

**\[KF 6285 .C6\]**

-   Federal Tax Coordinator 2d RIA

**\[KF 6285 .T3\]**

-   Internal Revenue Cumulative Bulletin

**\[KF 6300 .A552\]**

-   Lexis - Library: FEDTAX; File: TXLAWS

> **1. Legislative History**

Researching the legislative history of the IRC involves the same basic
processes you would use to research non-tax legislation. In the tax
context, key sources of legislative history are reports on tax bills
issued by the House Ways and Means Committee, the Senate Finance
Committee, or any Conference Committee, records of House, Senate, and
Conference Committee debates, statements, or hearings on proposed tax
legislation as reported in the *Congressional Record*, and *Blue Book*
renditions of the Joint Committee on Taxation (which technically are not
part of the statute's legislative history, but are nevertheless useful).
This type of information may be obtained through a variety of print or
on-line resources, including Lexis, Westlaw, Congressional Universe and
the free Web at the Library of Congress' THOMAS site
**\<http://thomas.loc.gov\>.** An important *caveat* about legislative
history: although it frequently is a bountiful source of information
about a tax law, it is not the tax law itself -- some legislative
history more accurately tracks the language finally adopted than others.
So -- while we can appreciate, and often find meaning in, what Congress
said about the bill before it was enacted into law, the words ultimately
approved by Congress are what control.

**B. Internal Revenue Service Releases**

> **1. Regulations**

Under IRC § 7805(a), the Secretary of the Treasury or the Secretary's
delegate has the general power to prescribe rules and regulations --
referred to as general or interpretive regulations -- to clarify the
language of the Code. Some Code sections may specifically independently
authorize the Secretary to promulgate rules needed to effectuate the
provisions; these regulations are known as legislative or statutory
regulations, and are viewed as having the force and effect of law. When
performing in-depth research of a Code provision, it is important to
consider whether an interpretive regulation accurately tracks what is
provided for by the Code, or whether it, in fact, reflects an effort on
the part of the Secretary to expand the reach or scope of the tax law
beyond what Congress intended. Recently-proposed or adopted Treasury
regulations are initially published in the Federal Register (these, of
course, do not have the force and effect of law, but are reflective of
how the Service proposes to administer the affected Code provision).
Final regulations are called Treasury Decisions (T.D.) and are given a
unique number. Adopted or proposed regulations are also found in the
following sources:

-   Internal Revenue Cumulative Bulletin (as well as in the weekly IRB)

**\[KF 6300 .A552\]**

-   Federal Tax Coordinator 2d (volumes 27 & 27A contain proposed
    regulations)

> **\[KF 6285 .T3\]**

-   The Federal Register

-   Also available through CCH Tax Research NetWork

```{=html}
<!-- -->
```
-   Code of Federal Regulations -- IRS regulations are found in Title
    26.

**\< http://www.gpoaccess.gov/uscode/browse.html \>**

The following sources contain subject arrangements of IRS regulations:

-   Code of Federal Regulations, Title 26

> **\[KF 70 .A3\]**

-   Federal Tax Regulations

> **\[KF 6301 .A4 1954\]**

-   Lexis -- Library: FEDTAX; file: TXLAWS

-   Westlaw -- Identifier: FTX-REG

The following resources, called "citators," are used to confirm that a
regulation or statute is still in force:

-   CCH Standard Federal Tax Reporter

**\[KF 6285 .C6\]**

(Use the Citator/Finding List volume)

> **2. Revenue Rulings**

Revenue rulings -- which have less authoritative force than Treasury
regulations -- are official IRS interpretations of tax laws or treaties
as applied to a specific set of facts, *see,* Treas. Reg. Sec.
601.201(a)(1). Because revenue rulings often may be revoked, superseded,
modified, or declared obsolete, it is imperative to determine that the
revenue ruling you are interested in continues to have viability. These
rulings of general interest are found in the following sources:

-   Internal Revenue Cumulative Bulletin (as well as in the weekly IRB)

**\[KF 6300 .A552\]**

-   Law of Federal Income Taxation

**\[KF 6369 .M4\]**

-   Lexis -- Library: FEDTAX; file: CB

-   Westlaw -- Identifier: FTX-RR

-   Internet: **\< http://www.taxlinks.com/ \>**

```{=html}
<!-- -->
```
-   Also available through CCH Tax Research NetWork

> **3. Revenue Procedures**

Revenue procedures differ from revenue rulings in that they do not
address application of Code provisions to specific fact patterns, but
instead are published by the IRS to inform the public of procedural
rules that affect taxpayers\' rights and duties. Depreciation guidelines
and tables are examples of items covered by official revenue procedures,
which are binding on the IRS and can be relied on by taxpayers. Revenue
procedures are found in the following sources:

-   Internal Revenue Cumulative Bulletin (as well as the weekly IRB)

**\[KF 6300 .A552\]**

-   CCH Standard Federal Tax Reporter

**\[KF 6285 .C6\]**

-   Lexis- Library FEDTAX; file: CB

-   Westlaw - Identifier: FTX-CB

-   Also available through CCH Tax Research NetWork

> **4. Letter Rulings**

Letter rulings, also referred to as private letter rulings, are issued
by the IRS when there is no clear authority for determining the tax
consequences of a particular transaction, provided the area is one in
which the IRS has determined that it will rule. The taxpayer initiates
the letter ruling process by requesting a ruling on a particular issue.
If the IRS issues a ruling, only the requesting taxpayer may rely on it.
However, many researchers use letter rulings as guidance on particular
issues. Letter rulings are found in the following sources:

-   P-H Federal Taxes: Private Letter Rulings (through 1988 only)

> **\[KF 6301 .A56 P7\]**

-   Lexis -- Library: FEDTAX; file: RELS or PLR

-   Westlaw -- Identifier: FTX-PLR

```{=html}
<!-- -->
```
-   Also available through CCH Tax Research NetWork

> **5. Other IRS Statements of Position**

a.  **Technical Advice Memoranda**

Technical Advice Memoranda (TAMs) are issued by the technical staff of
the national office of the IRS. Although they are similar to private
letter rulings, TAMs differ in that they resolve questions regarding
transactions that have already occurred. A TAM might be issued, *e.g.,*
during the course of an IRS audit in which issues arise that merit
issuance of technical advice. Employees of the IRS or the taxpayer may
initiate the request for technical advice.

-   Lexis - Library: FEDTAX; file: PLR

-   Westlaw - Identifier: FTX-PLR

```{=html}
<!-- -->
```
-   Also available through CCH Tax Research NetWork

    a.  **Actions on Decisions**

The Internal Revenue Service is bound by United States Supreme Court
decisions and cases in which *stare decisis* applies. Actions on
Decisions (AODs) may be prepared when the IRS loses a case in any
federal court other than the Supreme Court, and consist of
recommendations as to what course of action the IRS will adopt when it
loses a case. The text of the AOD -- which can take the form of an
acquiescence, an acquiescence in result only, or a non-acquiescence --
advises whether the IRS intends to adhere to the adverse decision when
confronted with similar circumstances. AODs are not intended as taxpayer
advisories, but instead are meant to advise IRS personnel who are
addressing the same, or similar, issues.

-   Lexis - Library: FEDTAX; file: MEMOS

-   Westlaw - FTX-AOD or FTX-MEMOS

> **c. General Counsel Memoranda**

General Counsel Memoranda (GCMs) are generated by the Office of Chief
Counsel, and are used to analyze and review proposed revenue rulings,
private letter rulings, and technical advice memoranda. Because GCMs
present a substantive legal analysis of issues, they help to discern the
IRS' perspective on the issues for use in connection with other tax
cases. \[Note that Field Service Advice (FSAs) are like GMCs, but were
phased out in 2002.\] GCMs are found in the following sources:

-   Lexis -- Library: FEDTAX; file: GCM or MEMOS

-   Westlaw -- Identifier: FTX-GCM or FTX-MEMOS

GCMs have no precedential status under IRC § 6110(k)(3), but
nevertheless have been considered by some courts in the context of a
particular case.

> **6. IRS Procedure**

The Internal Revenue Manual describes the procedural rules that IRS
personnel must follow, and is an extremely important source of
information about a variety of matters administered by IRS personnel.
The IRM does not have the force and effect of law, and is generally
viewed as not conferring enforceable rights on taxpayers. However, there
have been instances in which a litigant has successfully invalidated
agency action by contending that the agency's failure to adhere to the
prescriptions in its own manual have adversely affected the litigant's
substantive rights. A taxpayer can rely upon the IRM to defeat
negligence and substantial understatement penalties. It can be found in:

-   IRS Practice and Policy

**\[KF 6301 .A33\]**

-   Lexis - Library: FEDTAX; file: MANUAL

-   Westlaw - Identifier: FTX-IRM

-   Internet: \< http://www.irs.gov/irm/ \>

> **7. IRS Publications**

IRS publications are pamphlets that discuss specific tax topics in
detail. They are useful for practitioners, as well as the general
public. They can be found in the following sources:

-   RIA's Official IRS Publications

**\[KF 6289 .R53 1990\]**

-   Taxpayer Information Publications

**\[KF 6301 .A33 S45\]**

-   Lexis - Library: FEDTAX; file: TNTPUB

-   Westlaw - Identifier: FTX-IRSPUBS (1997) and FTX-IRSPUBS-OLD
    (1984-1996)

-   Internet - **\< http://www.irs.gov/formspubs/index.html \>**

```{=html}
<!-- -->
```
-   Also available through CCH Tax Research NetWork

> **8. IRS Forms & Instructions**

-   Internet - **\<http://www.irs.gov\>**

#### C. Federal Court Decisions {#c.-federal-court-decisions .unnumbered}

> **1. United States Tax Court**

The United States Tax Court (IRC § 7441) hears only tax cases. One of
its hallmarks is that the taxpayer is not required to pay the disputed
amount before filing suit. Trial by a jury is not available in the U.S.
Tax Court. Opinions of the U.S. Tax Court can be found in the following
sources:

-   United States Tax Court Reports, previously titled Reports of the
    United

States Board of Tax Appeals (Official reporter cited as: T. C.)

**\[KF 6324 .A514\]**

-   Tax Court Reporter

**\[KF 6324 .A515 C6R\]**

-   Tax Court Memorandum Decisions

**\[KF 6324 .A515 C6M\]**

-   T. C. Memorandum Decisions, previously titled B. T. A. Memorandum
    Decisions

**\[KF 6324 .A516 P7M\]**

-   Tax Court Reported and Memorandum Decisions

**\[KF 6324 .A516 P7\]**

-   Lexis - Library: FEDTAX; file: TCTCM and TC and TCM

-   Westlaw - Identifier: FTX-TCT

-   Internet - **\< http://www.ustaxcourt.gov \>**. Small tax case
    division (as well as other) decisions currently are published by the
    United States Tax Court on its website. The Federal Tax Court Rules
    of Practice & Procedure can also be found here.

```{=html}
<!-- -->
```
-   Also available through CCH Tax Research NetWork

2.  **Other Courts**

The United States Tax Court is one of three courts in which a taxpayer
can file a tax-related lawsuit. The other two courts are the U.S.
District Courts (based upon the location of the taxpayer\'s residence)
and the U.S. Court of Federal Claims. To obtain access to one of these
two alternate courts, the taxpayer must first have paid the tax and
sought a refund (so that the case is styled as a refund action). Jury
trials are available in the U.S. District Courts, but not in the U.S.
Court of Claims.

Adverse decisions from the U.S. Tax Court and the U.S. District Courts
are appealed to the applicable U.S. Circuit Courts of Appeals. Adverse
decisions from the U.S. Claims Court are appealed to the Federal Circuit
Court of Appeals. Adverse decisions of the U.S. Circuit Court of Appeals
and the Federal Circuit Court of Appeals level are appealed to the U.S.
Supreme Court.

The following sources publish tax-related opinions from the U.S.
District Courts, U.S. Court of Claims, U.S. Circuit Courts of Appeals,
Federal Circuit Court of Appeals, and the U.S. Supreme Court. They do
not include cases from the U.S. Tax Court.

-   Federal Supplement, West Publishing Company (published opinions of
    the U.S. District Courts)

-   U.S. Court of Federal Claims reporter, West Publishing Company
    (published opinions of the U.S. Court of Federal Claims) (note:
    before 10/29/92, the name of this court was the Claims Court;
    proceedings of that court are found in West's United States Claims
    Court Reporter, as well as in the Court of Claims Reporter (Ct. Cl.)
    published by the GPO; West's Federal Reporter 2d and 3d and West's
    Federal Supplement also together report on Court of Claims cases
    from 1929 to 10/29/92)

-   Federal Reporter, West Publishing Company (reported decisions of the
    Circuit Courts of Appeals)

-   United States Supreme Court Reports, GPO

-   Supreme Court Reports, West Publishing Company

-   Cumulative Bulletin (publishes U.S. Supreme Court decisions)

-   RIA's American Federal Tax Reports (AFTR & AFTR2d) (Advance sheets
    for this source are found in the RIA United States Tax Reporter
    **\[KF 6285 .P74**\])

> **\[KF 6280 .A2 P7\] (**Note: RIA's United States Tax Reporter is
> known as an "annotated service," and includes a multitude of
> information critical to tax researchers, including the Code,
> legislative history references, explanations, and annotations relating
> to the particular Code section.)

-   CCH's U.S. Tax Cases (USTC) (The advance sheets for this source are
    found in CCH Standard Federal Tax Reporter **\[KF 6285 .C6\]**,
    **\[KF 6280 .A2 C6\]**

*Note: Parallel citations to AFTR, AFTR2d or USTC from other reporters
(Federal Reporter 2d, 3d, Federal Supplement 2d, and etc.) can be found
in the Finding Tables volume of the Federal Tax Coordinator 2d* **\[KF
6285 .T3\]**.

-   Lexis - Library: FEDTAX; file: U.S. District Courts - DIST; U.S.
    Court of Claims -

CLAIMS; U.S. Circuit Courts of Appeals - USAPP; Federal Circuit Court of
Appeals -

CAFC; U.S. Supreme Court - US

-   Westlaw - Identifier: U.S. District Courts, U.S. Circuit Courts of
    Appeals, U.S.

Supreme Court - FTX-CS; U.S. Court of Claims - FTX-FEDCL; Federal
Circuit Court

of Appeals- CTAF.

-   Internet -

U.S. District Courts - **\<http://uscourts.gov/districtcourts.html\>**

U.S. Court of Claims - **\<http://www.uscfc.uscourts.gov/\>**

U.S. Circuit Courts of Appeal -
**\<http://findlaw.com/casecode/courts/index.html\>**

> or **\< http://www.uscourts.gov/courtsofappeals.html \>**

Federal Circuit Court of Appeals - **\<http://www.fedcir.gov/\>**

U.S. Supreme Court - **\<http://findlaw.com/casecode/supreme.html\>** OR

> **\<http://supct.law.cornell.edu/supct/\>** OR
> **\<http://www.supremecourtus.gov/\>**

**D. Case Citators**

-   Shepard\'s Federal Tax Citator

**\[KF 6280.5 .S46 1995\]**

-   Federal Taxes Citator

**\[KF 6280.5 .P72\]**

##### V. Secondary Sources

**A. Periodical/Journal Articles and Indexes**

-   Journal of Taxation

-   Tax Lawyer

-   Taxation for Lawyers

-   Tax Law Review

-   TAXES---The Tax Magazine

-   Legaltrac (index to articles) http://www.gale.com/tlist/sb5088.html

-   Index to Legal Periodicals (index to articles)

-   Index to Federal Tax Articles (index to articles)

-   Federal Tax Articles (index to articles)

-   Legal Resource Index (print and on Westlaw -- Identifier LRI)

-   Current Law Index (print index)

-   Lexis (full text articles) - Library: FEDTAX; file: TAXLR

-   Westlaw (full text articles) - Identifier: TX-TP

#### B. Current Awareness Sources/Newsletters {#b.-current-awareness-sourcesnewsletters .unnumbered}

-   Westlaw Newslink email alerts on tax issues

-   IRS Newswire http://www.gale.com/tlist/sb5088.html

-   IRS Guidewire
    <http://www.irs.gov/newsroom/page/0,,id=123315,00.html>

-   BNA Tax Management online <http://www.bnatax.com/tm/index.html>

-   CCH's Federal Tax Weekly (newsletter that comes with looseleaf set)

-   CCH's Taxes on Parade (part of Standard Federal Tax Reporter)

-   RIA's Weekly Alert (newsletter that comes with looseleaf set)

-   Tax Analysts Tax Notes (available in Lexis and in print)

-   Tax Analysts \< <http://www.taxanalysts.com/>\>

-   Deloitte & Touche's Tax News & Views \<
    http://deloitte.12hna.com/enews/\>

> **C. Monographs and Treatises**

Law library catalogs provide access to information about a wide variety
of tax treatises that are worthy of consultation for background
materials.

**\[**

**D. Looseleaf Treatises**

The following sets provide in depth discussion of various tax related
topics, they include examples and practical advice. These sets receive
heavy use by researchers.

-   BNA's Tax Management Portfolios; also on Westlaw and Lexis

**\[KF 6289 .A1 T35\]** (These are extremely detailed and valuable
resources arranged according to topic -- another example of a topical
service is RIA's Federal Tax Coordinator.)

-   Lexis - Library: FEDTAX; file: TMPORT

-   Westlaw - Identifier: FTX-ALL

-   Law of Federal Income Taxation (commonly known as Merten\'s)

**\[KF 6369 .M4\]**

-   Standard Federal Tax Reporter (CCH) -- online in CCH Tax Research
    Network

**\[KF 6285 .C6\]**

**E. Miscellaneous**

-   TaxCite: a Federal Tax Citation Reference Manual - This manual
    contains

citation forms and reference materials relating to federal taxation. It
should be used

in conjunction with The Bluebook: Uniform System of Citations.

**\[KF 245 .T39 1995\]**

-   US Master Tax Guide -- This annual publication is an excellent quick
    reference for

various tax questions -- online in CCH Tax Research Network.

**\[KF 6369 .C7\]**

**Acknowledgements: This guide in part incorporates materials prepared
by Janet Hedin and Jane Edwards of the Michigan State University College
of Law Library, by a former staff member of the law library, Carol
Parker, and by a former MSU College of Law student, Kristine Lipinski.
Professors Halloran and Campbell extend their sincere thanks for
permission to use these materials.**