The primary sources of Federal tax law are:
- The Internal Revenue Code, which is Title 26 of the United States Code;
- Decisions of the United States Tax Court, district courts, Court of Federal Claims, federal circuit courts, and the United States Supreme Court;
- Treasury Regulations, located in Title 26 of the Code of Federal Regulations;
- Internal Revenue Service guidance published in the Internal Revenue Bulletin, including Revenue Rulings, Revenue Procedures, Notices, and Announcements; and
- Other Internal Revenue Service material, including Private Letter Rulings and Technical Advice Memoranda.
It is important for the researcher to keep in mind the provisions of Treas. Reg. § 1.6662-4(d)(3) regarding "Substantial Authority." The types of materials that are substantial authority for the purposes of this Regulation include:
- The Internal Revenue Code
- Proposed, temporary, and final regulations
- Tax treaties and applicable regulations
- Court cases
- Congressional intent as reflected in committee reports
- General explanations on tax legislation by the Joint Committee on Taxation ("The Blue Book")
- Private Letter Rulings issued after October 31, 1976
- Actions on decisions
- General Counsel Memoranda
- IRS Press Releases
-
Notices, announcements, and other administrative pronouncements
published by the IRS in the Internal Revenue Bulletin
