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, for example:

• 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, and Checkpoint Edge.

• Code of Federal Regulations. KF70.A3 - 9th Floor. Also available via HeinOnline and freely through the GovInfo website.
• West's Code of Federal Regulations. KF70. A34 9th Floor. A good topical index to locate relevant CFR sections.
• Standard Federal Tax Reporter. KF6365.S73 10th Floor. Tax regulations can be found next to the associated code provisions. Also available via VitalLaw.
• Federal Register. KF70.A2 - 9th Floor. Available via HeinOnline and GovInfo.

The IRS also issues administrative interpretations of the Code. These take the form of rulings that indicate the position the IRS may take in applying tax law to a certain set of facts. These rulings can be 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.): KF6301.A4 - 10th Floor. The IRS also provides online access to bulletins going back to 1995.
• Internal Revenue Cumulative Bulletin (I.R.C.B.): KF6301.A4- 10th floor. This set compiles the rulings first published in the I.R.B.
• Standard Federal Tax Reporter: KF6365 .S73 - 10th Floor. Also available via VitaLaw.
• The FOIA Library 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 Private Letter Rulings, as well as other guidance documents, are found under the Non-Precedential Rulings and Advice section of the page.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. KF241.T38 R5 2018 - 6th Floor (Reserve).

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

The FOIA Library at the IRS website contains many of these materials as well.