Tax Research
The method behind every article on this site: reading statutes and regulations, weighing rulings and cases, tracing legislative history, using citators, and building a research file that supports a position under Circular 230 standards.
Start here
3 piecesNo background assumed — the pieces that build the foundation.
Guide · Intro · 8 min
The free tax research stack: primary authority without a subscription
Every layer of federal tax authority — Code, regulations, rulings, cases, legislative history — is available free from government sources. Here is the complete workflow, with a worked Section 41 example.
Brief · Intro · 3 min
Building a research file: the memo that defends the position
A tax research file is a dated memo — issue, facts, law, analysis, conclusion — plus the authorities it relies on, saved as found. Done contemporaneously, it is the backbone of both the position and any later penalty defense.
Brief · Intro · 3 min
Revenue rulings vs. revenue procedures: what each one is and what it's worth
A revenue ruling states the IRS's position on how the law applies to facts; a revenue procedure tells taxpayers how to do something. Both are published in the Internal Revenue Bulletin, and their weight differs from both regulations and private rulings.
The working layer
6 piecesThe practitioner's day-to-day rules, mechanics, and traps.
Guide · Working · 8 min
How to read a tax case: forum, posture, holding, and weight
A tax opinion's value depends on which court decided it, in what posture, and what it actually held versus merely said. Here is the anatomy of a tax case and how to brief one for a research file.
Brief · Working · 3 min
Researching state tax law: statutes, conformity, and where the free sources hide
State tax research runs the same statute-regulation-ruling ladder as federal, plus one extra step: tracing how the state conforms to the Internal Revenue Code. Here is the method and where the free sources live.
Brief · Working · 3 min
The substantial authority standard: weighing what you found
Substantial authority under Section 6662 is an objective weighing of listed authorities for and against a return position — roughly a 40% standard. Here is the authority list, the weighing rules, and how credit positions typically score.
Brief · Working · 3 min
Is it still good law? Checking currency without a paid citator
Shepard's and KeyCite are conveniences, not necessities. Subsequent-history tracing, IRB status lines, and actions on decision let you verify that a case or ruling is still good law using only free government sources.
Brief · Working · 3 min
PLRs, TAMs, and Chief Counsel memoranda: reading guidance that binds no one
Private letter rulings, technical advice memoranda, and Chief Counsel advice cannot be cited as precedent under Section 6110(k)(3) — yet they are among the most revealing documents the IRS releases. Here is what each binds, and how to use them anyway.
Brief · Working · 3 min
Why regulation preambles matter more than most practitioners think
The preamble to a Treasury regulation explains what the rule means, when it applies, and which taxpayer arguments Treasury already rejected — or conceded. It is free at federalregister.gov and routinely decisive.
Pro details
1 piecesSpecialist nuance: edge cases, interactions, and planning.