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Research Guides

ACCT 621 Introduction to Taxation of Corporations (Fall 2021)

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

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