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ACCT 621 Introduction to Taxation of Corporations (Fall 2016)

Tax Research Process

  1. Establish the facts
    • Understand the tax transaction 
    • Try the 5W and H method: who, what, where, when, why, and how
  2. Identify the issues
    • Use to formulate the tax research questions
  3. Locate authority
    • Utilize various search methods to find sources
  4. Evaluate authority
    • Try the 5W and H method to evaluate resources
    • Remember: Primary sources have more authority than secondary
  5. Develop conclusions and recommendations
  6. Communicate recommendations
  1. State the issue as a question.
  2. Identify keywords.
  3. Construct a computer research query.
  4. Select a database and execute the search.
  5. Interpret and refine the search.
  1. Keyword
  2. Citation (code section, case name, etc.)
  3. Table of Contents
  4. Date range
  5. Index
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Primary Sources (Original Pronouncements)

Statutory Sources

  • U.S. Constitution - source of federal tax laws
  • Tax Treaties - agreements negotiated between countries concerning the treatment of entities subject to tax in both countries
  • Internal Revenue Code - collection of laws that have been passed by Congress and incorporated in Title 26 of the United States Code.

Administrative Sources

  • Treasury Regulations - constitute the IRS's and, thereby, the Treasury's official interpretation of the Internal Revenue Code
  • Revenue Rulings - official pronouncements of the National Office of the IRS; deals with the application of the Code and Regulations to a specific factual situation
  • Revenue Procedures - internal practice and procedures of the IRS in the administration of tax laws; constitute the IRS's way of releasing information
  • Other Written Determinations
  • Miscellaneous IRS Publications

Judicial Sources

  • Supreme Court
  • Courts of Appeals
  • District Courts
  • U.S. Court of Federal Claims
  • Tax Court
  • Tax Court, Small Cases Division

Secondary Sources (Interpretations of Primary Authority)

  • Tax Services - coordinated sets of reference materials that organize the tax authority into a usable format
    • Annotated - organized by Internal Revenue Code section number
    • Topical - divide tax law into transactions and related subject matter with underlying tax principles as an organizing format
  • Tax Citators - tool through which a tax researcher can learn the history of a case or ruling and evaluate the strengths of its holdings
  • Tax Treatises - agreements negotiated between countries concerning the treatment of entities subject to tax in both countries
  • Tax Journals
  • Tax Newsletters
  • Tax Textbooks