Primary Sources in Checkpoint

American Federal Tax Reports (1860 – 2003) - The AFTR series contains decisions of federal tax cases that were not heard in Tax Court. AFTR includes:

• All U.S. Supreme Court Cases that deal with federal taxes
• All U.S. Court of Appeals cases that deal with federal taxes
• All significant District and Claims court cases that deal with federal taxes

American Federal Tax Reports (Current Year)

The full text of tax cases gives you the complete history of all tax cases. Each case is preceded by time-saving headnotes which identify the issues and summarize the Court’s finding and rationale.

Tax Court & Board of Tax Appeals Memorandum Decisions (1928 - 2003) - the full text of all reported and memo decisions that address new issues and require revision to an existing law or a new law.

Tax Court & Board of Tax Appeals Reported Decisions (1924 - 2003)

Tax Court & Federal Procedural Rules - the full text of all Tax Court Rules and Federal Rules of Appellate Procedure.

Tax Court Memorandum Decisions (Current Year)- the full text of all reported and memo decisions and features official pagination as it appears in the GPO U.S. Tax Court Reports.

Tax Court Reported Decisions (Current Year) - the full text of all Tax Court Decisions that address new issues and require revision to an existing law or a new law.

Tax Court Summary Opinions

An invaluable reference addressing the rapidly changing and increasingly complex area of tax procedure. This well-regarded authority can be a practitioner’s single most important tool to understanding the procedural changes, IRS restructuring, as well as the ongoing revision of the Internal Revenue Manual.

This unique, 2,000-page treatise has more than 400 references to the Internal Revenue Manual and more than 5,000 case citations, as well as references to thousands of critical Treasury regulations, revenue rulings, revenue procedures, and IRS internal advice.

Topics include:

• IRS Telephone Directory
• Ethics Materials
• How to Use the Internal Revenue Manual
• Internal Revenue Manual Index
• ISP Materials
• Internal Revenue Manual
• MSSP Training Guide
• Market Segment Understandings Guidelines

IRS Publications

The full text of all IRS publications, organized by publication number.

Actions on Decisions (1967 - Present) - Prepared when the IRS loses an issue/issues in a court case. Issued by the Chief Counsel Office. Recommends action (other than Tax Court) that the IRS should take in response to the adverse decision.

Announcements (1959 - Present) - Usually general interest content.

Chief Counsel Advice - Generated by the Chief Counsel’s Office, by request from the IRS, usually to assist in the preparation of a Rev. Rul. or PLR.

Delegation Orders (1956 - Present) - Generated by the Treasury Department. Government officials cannot legally do anything without the authority required by law. How they get the authority to do something is by the authority being delegated to them, which gives them permission to perform a particular function or act.

Executive Orders - Generated by the chief executive (President or state governor). Government officials cannot legally do anything without the authority required by law. How they get the authority to do something is by the authority being delegated to them, which gives them permission to perform a particular function or act.

Field Service Advice - IRS Field Service Advice ( FSA) Memorandums are released by the IRS Office of Chief Counsel to provide consistent legal advice to IRS Field Service and related IRS functions with respect to their tax administration responsibilities.

General Counsel Memoranda (1962 - Present) - Generated by the Chief Counsel’s Office, by request from the IRS, usually to assist in the preparation of a Rev. Rul. or PLR.

IRS News Releases - released by IRS's Public Affairs Office whenever there is information of importance that needs to be released to the public. Many News Releases pertain to tax treatment of items that you will either be deducting, expensing, or including as income on your tax return.

IRS Business Operating Divisions - Reports and documents released by the IRS Business Operating Divisions (Advance Pricing Program and Large and Mid-Size Business)

Notices (1980 - Present) - Provide substantive or procedural tax law guidance.

Other FOIA (Freedom of Information Act) Documents - Other IRS documents available through the FOIA.

Other IRS Documents - Miscellaneous IRS documents.

Private Letter Rulings & Technical Advice Memoranda (1953 – Present) - IRS issues PLRs when taxpayer wants to know the IRS’s position on either a proposed transaction or one that has occurred, but has not been reported. TAMs are similar to PLRs except that it involves a completed transaction.

Revenue Procedures (1955 - Present) - IRS issues as a way of releasing information to taxpayers. Rev Procs usually deal with IRS practice & procedure which affect rights or duties of taxpayers.

Revenue Rulings (1954 - Present) - Purpose is to provide guidance to taxpayers and IRS officials. Rev Ruls usually deal with the application of Code and Regs. to a specific factual situation.

Service Center Advice - IRS Service Center Advice ( SCA) Memorandums are released by the IRS Office of Chief Counsel to provide consistent legal advice to IRS service centers and related IRS functions with respect to their tax administration responsibilities.

Treasury Technical Explanations, Senate Committee Reports, Reports of the Secretary of State, and other related documents are also included. Look to this database for the latest cases and rulings along with the status and content of new treaties and protocols. All are accompanied by annotated summaries and additional direct links to article-by-article analysis.