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Federal Tax Research Guide

A guide to conducting federal tax research.

Special Bluebook Citing Rules


Please note that there are special Bluebook citation rules for tax-related administrative materials and court cases (see Bluebook (19th ed.) pp. 221 - 223.)


Electronic Databases

Tax opinions are available electronically in the specialized tax databases CCH Intelliconnect and Thomson Reuters Checkpoint.

On WESTLAW, tax decisions are in the FTX-CS database.

On Lexis, select Topic-Taxation, then choose from the available "Find federal tax cases" databases.

Tax Cases

There are three forums for tax litigation: the United States Tax Court, the United States district courts, and the Court of Federal Claims. The Tax Court is a "deficiency forum," meaning that the case is litigated by a taxpayer who owes taxes. The district courts and the Court of Federal Claims are "refund forums," meaning that the case is litigated by a taxpayer who is alleging that he is due a refund.

Tax Court cases have the title Taxpayer v. Commissioner.

Refund cases have the title Taxpayer v. United States.

Appeals from the Tax Court or the district court are made to the Circuit Court of Appeals coverning the taxpayer's state of residence. Appeals from the Court of Federal Claims are made to the United States Court of Appeals for the Federal Circuit. 

Tax cases are published in both official reporters and unofficial commercial reporters.

Tax Court Decisions

The United States Tax Court issues three types of decisions: (1) summary opinions, (2) regular decisions, and (3) memorandum decisions.

Summary opinions are issued in "small tax" cases, which are litigated through an expedited process and cannot be appealed. These decisions, until recently, were not published and are not precedent in any cases.

Regular decisions are "published" decisions of the Tax Court. They are published officially in the United States Tax Court Reports (T.C.). Before 1942, the Tax Court was the "Board of Tax Appeals", and its decisions were published in the Board of Tax Appeals Reports (BTA). Regular decisions are also commercially published in CCH's Tax Court Reporter.

Memorandum decisions are "unpublished" decisions of the Tax Court. They typically concern factual issues involving settled issues of tax law. They are unofficially published in the commercial reporter Tax Court Memoradum Decisions (T.C.M.). Both CCH and Thomson Reuters (formerly RIA) have competing versions of this reporter, so proper citation is to "T.C.M. (CCH)" or "T.C.M. (RIA)" as applicable. Tarlton maintains only the CCH version in print.

Tax Decisions of District Courts, the Court of Federal Claims, Courts of Appeal

Reported tax decisions of the district courts, Court of Federal Claims, and the Circuit Courts of Appeal are printed in the reporter applicable to that court, just like any other opinion.

Reported tax decisions and "unreported" tax decisions from these courts are also printed in two commercial print reporters: United States Tax Cases (USTC) and American Federal Tax Reports (AFTR). USTC is published by CCH, and AFTR is published by Thomson Reuters (formerly RIA). Each reporter integrates with the applicable publisher's print and electronic finding aids (CCH's Standard Federal Tax Reporter & CCH Intelliconnect; Thomson Reuters's United States Tax Reporter, Federal Tax Coordinator, and Thomson Reuters Checkpoint).

Tarlton's set of USTC is kept current; the subscription to AFTR ended in 2007.