Federal Tax Research: Administrative Materials

Important guides for clarifying the Code's meaning are the regulations issued by the U.S. Department of the Treasury. There are different types of regulations: Proposed, Temporary, and Final. In citations to temporary and final regulations the number after the decimal point corresponds to the Code section related to the regulation, e.g.,                    

            Temp. Treas. Reg. §1.181-1T relates to §181 of the Code.

            Treas. Reg. §1.112-1 relates to §112 of the Code.

Temporary and final regulations, issued as Treasury Decisions (T.D.s), can be found in title 26 of the Code of Federal Regulations (C.F.R.) and  proposed regulations can be located in the Federal Register. All three types of regulations are also available in Westlaw, Lexis, Checkpoint, and Bloomberg Law.

• Code of Federal Regulations. [Washington]: U.S. General Services Administration, National Archives and Records Service, Office of the Federal Register; U.S. Govt. Printing Office, 1949. [KF70 .A3 9th fl].Also available through   HeinOnline and freely through the GovInfo website.
   
• West's Code of Federal Regulations. General Index. [St. Paul] , MN: West Pub. Co, 2006-. [KF70. A34 9^th Fl]. A good topical index to locate relevant CFR sections.
   
•  Standard Federal Tax Reporter. Chicago, Ill: Commerce Clearing House, 1945-. [KF6365 .S73 10^th fl].  Tax regulations can be found next to the associated Code provisions. 
   
• Federal Register. Washington, D.C: Office of the Federal Register, National Archives and Records Service, General Services Administration. Availabe via HeinOnline, and GovInfo.    

The IRS also issues administrative interpretations of the Code. These take the form of rulings which indicate what the position the IRS may take in applying tax law to a certain set of facts. These rulings can be either Revenue Rulings (Rev. Rul.) or Private Letter Rulings (Ltr. Rul, Priv., Ltr. Rul.) Revenue Rulings are those the IRS decides are of general interest. Letter Rulings are IRS responses to requests by individual taxpayers for guidance regarding the consequences of contemplated transactions. IRS Rulings can be found in Westlaw, Lexis, and Checkpoint in addition to print sources.

• Internal Revenue Bulletin (I.R.B.). Washington, D.C.: Dept. of the Treasury, Internal Revenue Service, 1953-. (I.R.B.). KF6301 .A4 10^th floor. The IRS also provides online access to bulletins going back to 1995.
• Internal Revenue Cumulative Bulletin. Washington, D.C.: Dept. of the Treasury,   Internal Revenue Service, 1969. (I.R.C.B.) KF6301 .A4  10^th floor. This set compiles the rulings first published in the I.R.B.
• Standard Federal Tax Reporter. Chicago, Ill: Commerce Clearing House, 1945. KF6365 .S73 10^th floor.
• The Reading Room at the IRS website contains Internal Revenue Bulletins under the Published Tax Guidance section of the page. Private Letter Rulings as well as other guidance documents are found under the Non-Precedential Rulings and Advice section of the page.

Besides rulings, the IRS also issues numerous other pronouncements and internal memoranda which are not binding but may nonetheless provide guidance. Samples of such documents are:

• Technical Advice Memoranda (T.A.M.) 
• General Counsel Memoranda (G.C.M.)
• Technical Memoranda (T.M.)
• Actions on Decisions Memoranda (A.O.D.)

For more background on these documents consult Gail Richmond's Federal Tax Research.

The most convenient sources for these documents are specialized tax databases such as BNA and Checkpoint or tax libraries within Westlaw and LexisNexis.

The Reading Room at the IRS website contains many of these materials as well.

Users will need to provide their assigned Westlaw or LexisNexis login and password information when selecting links to those databases.

For other databases, such as Bloomberg Law and RIA checkpoint, links should lead directly to the resources if accessed from on-campus. If used off-campus, users will need to enter their UIC NETID and password to access the databases after selecting the database link.