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Federal Tax Research Guide

Internal Revenue Service

"The Office of the Commissioner of Internal Revenue was established by act of July 1, 1862 (26 U.S.C. 7802). The Internal Revenue Service (IRS) is responsible for administering and enforcing the internal revenue laws and related statutes, except those relating to alcohol, tobacco, firearms, and explosives. Its mission is to collect the proper amount of tax revenue, at the least cost to the public, by efficiently applying the tax law with integrity and fairness. To achieve that purpose, the IRS strives to achieve the highest possible degree of voluntary compliance in accordance with the tax laws and regulations; advises the public of their rights and responsibilities; determines the extent of compliance and the causes of noncompliance; properly administers and enforces the tax laws; and continually searches for and implements new, more efficient ways of accomplishing its mission. IRS ensures satisfactory resolution of taxpayer complaints; provides taxpayer service and education; determines, assesses, and collects internal revenue taxes; determines pension plan qualifications and exempt organization status; and prepares and issues rulings and regulations to supplement the provisions of the Internal Revenue Code.

"The source of most revenues collected is the individual income tax and the social insurance and retirement taxes. Other major sources are corporate income, excise, estate, and gift taxes. Congress first received authority to levy taxes on the income of individuals and corporations in 1913, pursuant to the 16th Amendment of the Constitution."


Source: "Internal Revenue Service." The United States Government Manual. Washington, D.C.: Office of the Federal Register, National Archives and Records Service, General Services Administration.

Internal Revenue Manual

The Internal Revenue Manual is the official compendium of internal guidelines for IRS personnel and "serves as the single official compilation of policies, delegated authorities, procedures, instructions, and guidelines relating to the organization, functions, administration, and operations of the Service." (IRM Performance Management §1.4.1.7)

Tax lawyers consult the Internal Revenue Manual in order to determine if IRS employees are not following their own official guidelines.


The Internal Revenue Manual is available from the following resources:

Internal Revenue Bulletin and Cumulative Bulletin

Internal Revenue Bulletin (IRB)
 
The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for the publication of official rulings and procedures of the Internal Revenue Service, including all rulings and statements of procedure which supersede, revoke, modify, amend, or affect any previously published ruling or procedure.  The Bulletin also includes the Commissioner's acquiescences and nonacquiescences in decisions of the U.S. Tax Court (other than decisions in memorandum opinions), Treasury decisions, Executive orders, tax conventions, legislation, court decisions, and other items considered to be of general interest.  (26 C.F.R. § 601.601)
 

Internal Revenue Cumulative Bulletin (CB)

"The contents of the weekly Bulletins were consolidated semiannually into permanent, indexed, Cumulative Bulletins through the 2008-2 edition."  (IRB 2013-32 pg. 24.)  The IRS ceased publication of the Cumulative Bulletin with the 2008–2 edition.  The official title is Internal Revenue Cumulative Bulletin.


Documents published in the Internal Revenue Bulletin and Cumulative Bulletin include: 
  • Actions on Decisions
  • Announcements
  • Executive Orders
  • Legislation
  • Notices
  • Proposed, temporary and final Regulations
  • Revenue Procedures
  • Revenue Rulings
  • Tax Conventions
  • Treasury Decisions (temporary and final regulations with preamble)

The Internal Revenue Bulletin is published weekly and is available from the following resources:

The Cumulative Bulletin is available from the following resources:

Types of IRS Guidance Documents (Pronouncements)

A Revenue Ruling is an official interpretation by the Service that has been published in the Internal Revenue Bulletin. Revenue Rulings are issued only by the National Office and are published for the information and guidance of taxpayers, Internal Revenue Service officials, and others concerned.  (26 C.F.R. § 601.601)
 
Revenue Rulings are officially published in the Internal Revenue Bulletin and Cumulative Bulletin
 
Revenue Rulings are numbered by year with two segments -- the year and the sequential number of the ruling for that year, e.g., Rev. Rul. 56-472 or  Rev. Rul. 2008-35.
A Revenue Procedure is a statement of procedure that affects the rights or duties of taxpayers or other members of the public under the Code and related statutes or information that, although not necessarily affecting the rights and duties of the public, should be a matter of public knowledge. (26 C.F.R. § 601.601(d)(2)(i)(b))
 
Revenue Procedures are officially published in the Internal Revenue Bulletin and Cumulative Bulletin
 
Revenue Procedures are numbered by year with two segments -- the year and the sequential number of the ruling for that year, e.g., Rev. Proc. 64-30 or  Rev. Proc. 2008-72.

Notices are public announcements issued by the Internal Revenue Service. Notices appear in the Internal Revenue Bulletin and are included in the bound Cumulative Bulletin. Notices are identified by a two digit number representing the year and a sequence number, e.g., Notice 95-67, 1995-2 C.B. 343.

Announcements are public pronouncements on matters of general interest, such as effective dates of temporary regulations, clarification of rulings and form instructions. They are issued when guidance of a substantive or procedural nature is needed quickly. Announcements can be relied on to the same extent as revenue rulings and revenue procedures. Announcements are identified by a two digit number representing the year and a sequence number, e.g., Announcement 96-124, 1996-49 I.R.B. 22  (I.R.M. 4.10.7.2.4.1)

A Private Letter Ruling (PLR) represents the conclusion of the Service for an individual taxpayer. The application of a private letter ruling is confined to the specific case for which it was issued, unless the issue involved was specifically covered by statute, regulations, ruling, opinion, or decision published in the Internal Revenue Bulletin.   (IRM 4.10.7.2.10)

Private Letter Rulings are taxpayer-initiated and are only binding between the IRS and the taxpayer who initiates the ruling.

Technical Advice Memorandums (TAM) are requested by IRS area offices after a return has been filed, often in conjunction with an ongoing examination. TAMs are binding on the Service in relation to the taxpayer who is the subject of the ruling.  (I.R.M. 4.10.7.2.10)

General Counsel Memorandums (GCM) are legal memorandums from the Office of Chief Counsel prepared in connection with the review of certain proposed rulings (Rev. Ruls., PLRs, TCMs) . They contain legal analyses of substantive issues and can be helpful in understanding the reasoning behind a particular ruling and the Service’s response to similar issues in the future.  (I.R.M. 4.10.7.2.11)

Actions on Decision (A.O.D.) include notices of acquiescence (acq.) and nonacquiescence (nonacq.).  These notices provide recommendations as to whether or not the IRS will continue to litigate an issue it has lost in a judicial proceeding, as well as the reasoning for the recommendation.

The Internal Revenue Bulletin also includes disbarment notices and delegation orders (Del. Order) announcing delegations of authority to various IRS offices.

IRS Forms and Publications

From the IRS website (IRS.gov) choose the "Forms & Pubs" tab and choose from current forms & publications or prior year forms and publications.

Finding Forms and Instructions

From either the current forms & publications page or the prior year forms and publications page, the "Find" box allows you to filter the list to find a specific product. The default setting is to find by product number.  Instructions are available that provide more information on searching forms.

 

IRS Website

The IRS website (www.irs.gov) is a source for the following publications and resources:


The IRS website has a page with information about the Tax Code, Regulations and Official Guidance.   

The page "Basic Tools for Tax Professionals" provides access to research materials, such as the code and regulations, the Internal Revenue Bulletin, and the Internal Revenue Manual.

Search the full text of IRS documents on the IRS website by using the advanced site search.

IRS Electronic Reading Room

The IRS Electronic Reading Room provides access to all of the IRS documents available on its website. This includes the Publications and Notices, the Internal Revenue Bulletin, Actions on Decisions, Chief Counsel Notices, and more. The easiest way to get to this page is to use a direct link instead of trying to get there from the IRS homepage.

Other Online IRS Resources

Instead of going to the IRS Electronic Reading Room, some IRS resources are available from the main IRS website.

  • Forms and Publications: If you already know the form or publication you are looking for, current and prior year forms and publications are available on the Forms & Pubs page, which can be reached by clicking on the tab at the top of the page.

 

  • Tax Statistics: on the bottom of the IRS website, there is a link to the Tax Stats, Facts, & Figures page. There is a wide range of data available, from the number of income tax returns filed with a particular form in a particular year to tax data on parternships grouped by size of total assets.

 


  • Tax Map: This resource is technically not housed on the IRS webpage, but you can get to it by running a search for "Tax Map" in the search box in the upper-right hand corner of the page. You can also go straight to the Tax Map with this link. The Tax Map is a database of information arranged by tax topics. Each topic page provides links to relevant webpages, forms, and publications (see the example topic page below). It is run by the National Technical Information Service.

 

Commercial Databases

To discover what IRS publications are available in Bloomberg Law, click on the “Practice Centers” tab and then choose “Tax.”  Under “Practice Pages,” choose “Federal Tax” and scroll down to “Laws & Regulations” and “Agency Documents.”

To discover what IRS publications are available in Lexis Advance, click on Browse.  Browse by category, and choose Administrative Materials.  Click on the letter "I" and you can find IRS publications listed either under "Internal Revenue" or "IRS."

For most publications you can choose from one or more of the following options:

  • Get Documents
  • Add source as a search filter
  • access the Table of Contents.

To discover what IRS publications are available in WestlawNext, from the All Content tab, choose Administrative Decisions and Guidance. 

Under the Federal category, select Internal Revenue Service. 

From this point, you can search the entire database of IRS materials, or you can select an individual title or document type, such as the Cumulative Bulletin or Private Letter Rulings.