Federal Taxation: A Research Guide
By Ann Kitchel, Creighton University Law Library
I. The Looseleaf Services
Traditionally, tax research revolves around one of the two major tax looseleaf services.
The services are designed to be one-stop shopping for the tax professional. Updated
weekly, the services share similar characteristics:
*Material is arranged by code section. For each code section, the following information
is included:
*Text of the code section
*Detailed references to the code section's legislative history
*Text of all final, proposed and temporary regulations
*Editorial comments and explanation
*Annotations to case law and rulings
Standard Federal Tax Reporter
KF6285.S67
Published by Commerce Clearing House (CCH) since the 16th Amendment
was ratified in 1913, this is perhaps the most well know and highly used tax
service. Consists of 20 volumes arranged by code section. Also includes
the complete IRC, a case citator and the advance sheets to United States Tax
Cases (USTC).
United States Tax Reporter
KF6285.U55
Published by Research Institute of America (RIA), this tax service is an
alternative to Standard Federal Tax Reporter. Similarly arranged by code
section and includes the complete IRC, case citator, annual volumes of IRS
Rulings and Legislative Proposals and the advance sheets to American
Federal Tax Reports, 2d Series (AFTR2d).
II. The Internal Revenue Code: Title 26 of the United States Code
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A. Development
"The Congress shall have the power to lay and collect taxes on income, from whatever
source derived, without apportionment among the several States, and without regard to
any census or enumeration." U.S. Const. amend. XVI.
With the ratification of the 16th Amendment to the U.S. Constitution in 1913, our present
system of income taxation began. The Revenue Act of 1913 also referred to as the Tariff
Act of 1913, was quickly passed after the new Amendment was ratified. For about the
next 20 years, Congress enacted several self-contained Revenue Acts that comprised the
entire income tax law of the United States. As tax law became more complex, Congress
passed the Internal Revenue Code of 1939, the first codified version of the tax code. The
1939 code was revised and reorganized again in 1954. Substant ial revisions took place
with the passage of the Tax Reform Act of 1986 and consequently the code was renamed
the Internal Revenue Code of 1986. Although tax laws have been amended over the
years since 1986, no major reorganization has taken place since then. The official title of
U.S. tax law is the Internal Revenue Code of 1986, as Amended.
B. Legislative Process
Revenue bills originate in the House of Representatives. The actual work on revenue
bills take place in the House Ways and Means Committee. After hearings take place the
Committee will issue a report. An important piece of legislative history, this report
includes the proposed bill, an analysis of its effect on revenue and a general explanation
of the purpose of the bill. Since this constitutes the only official document detailing the
reasoning of the committee's actions, it is an important source of information for the IRS,
the courts and practitioners. Once passed by the House the bill proceeds to the Senate
Finance Committee who will also issue a report. The Senate may pass their own version
of the bill or amend the House version. This often results in a Conference Committee
and another report.
C. Organization
The IRC is organized into several levels:
1. Subtitles
2. Chapters
3. Subchapters
4. Parts
5. Subparts
6. Sections
There are eleven subtitles:
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Subtitle
A
B
C
D
E
F
G
H
I
J
K
Topic
Income Taxes
Estate and Gift
Employment Taxes
Miscellaneous Excise Taxes
Alcohol, Tobacco and Certain Other Excise Taxes
Procedure and Administration
The Joint Committee on Internal Revenue Taxation
Financing the Presidential Election Campaign
Trust Fund Code
Coal Ind ustry Health Benefits
Group Health Plan Requirements
Chapters
1-6
11-14
21-25
31-47
51-54
61-80
91-92
95-96
98
99
100
The bulk of income tax provisions are in Subtitle A, Chapter 1. There are 22 subchapters
in chapter 1:
A Determination of Tax Liability
§§1-59A
B Computation of Taxable Income
§§61-291
C Corporate Distributions and Adjustments
§§301-385
D Deferred Compensation
§§401-424
E Accounting Periods and Methods
§§441-483
F Tax-Exempt Organizations
§§501-530
G Corporations Used to Avoid Income Tax
On Shareholders
§§531-565
H Banking Institution
§§581-597
I Natural Resources
§§611-638
J Estates, Trusts, and Beneficiaries
§§641-692
K Partners and Partnerships
§§701-777
D. Access
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L Insurance Companies
§§801-860L
N International Taxation
§§861-999
O Gain or Loss on Disposition of
Property
§§1001-1092
P Capital Gains and Losses
§§1201-1298
Q Readjustment of Tax Between
Years and Special Limitations
§§1301-1358
S S Corporations and their
Shareholder
§§1361-1379
T Cooperatives and their Patrons
§§1381-1388
U Empowerment Zones
§§1391-11397F
V Title 11 Cases
§§1398-1399
W District of Columbia
§§1400-1400C
X Renewal Communities
§§1400E-1400J
In addition to the United States Code itself, the IRC is available in the looseleaf services,
in handy desk versions and free on the Internet. A good site which allows researchers to
browse the IRC or search by key word is at Cornell's Legal Information Institute:
www4.law.cornell.edu/uscode/26/
E. Legislative History
To determine the legislative history of a code section, the best place to start is in one of
the tax looseleaf services. Arranged by code section, each section will include extensive
notes on the legislative history of the section. Excerpts of Committee Reports are often
included. Citations to Committee Reports found in the looseleaf services can be located
in full textin standard legislative history sources such as United States Code,
Congressional and Administrative News and Congressional Information Service. When
major tax legislation is passed, the services often publish individual booklets containing
the legislative history of the Act.
Rabkin & Johnson's Federal Income, Gift & Estate Taxation, located at KF6335.R284 is
another way to access legislative history by code section. The last six volumes contain
extensive legislative history information arranged by code section including the text of
selected Committee Reports.
For more comprehensive legislative history information, consult the set called, Internal
Revenue Acts published by West Group and located at in the library at: KF6275.99.U54.
This annual service prints all laws or portions of laws that amend the IRC each year. The
service dates back to 1954 but does not include the legislative history of the Tax Code of
1954. In addition to the text of the laws, corresponding legislative history in the form of
Committee Reports are also reprinted.
The legislative history of the 1954 Tax Code is available on microfiche. The title is:
Internal Revenue Acts of the United States: the Revenue Act of 1954 with Legislative
Histories and Congressional Documents. The call number is: KF6275.8 1982.
Legislative histories are also published in the IRS Cumulative Bulletin. For example the
legislative history of the Tax Code of 1939 is set out at 1939-1 C.B. 554. Consult
Appendix 3-1 of chapter 3 of Chanin, Specialized Legal Research, Aspen Law &
Business (1997) KF240.S64 for a complete listing of legislative histories published in the
Cumulative Bulletin through 1998. In addition, chapter 3 of Chanin's treatise provides
detailed descriptions of other sources for historical legislative history research.
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III. Administrative Materials
A. Regulations
1. Form
Treasury Regulations take two forms:
Legislative: In certain areas of tax law, Congress may choose not to specify the detailed,
usually technical provisions of a tax law and delegates this authority to the IRS. In this
type of regulation, the IRS specifies the substantive requirements of a tax provision and
as such, carries the authority of the statute itself and is difficult to challenge by a
taxpayer.
Interpretive: Congress gives the IRS the authority to interpret the Code through the
Regulations. In addition to the official IRS interpretation, helpful examples are often
provided to demonstrate the application of a tax provision.
2. Creation
Proposed Regulations: Like all administrative regulations, a tax regulation must start out
as a Proposed Regulation in the Federal Register. A Proposed Regulation is issued as a
Treasury Decision or TD. A period of time is allowed for comment. A Proposed
Regulation does not have the force of law until it is finalized.
Temporary Regulations: When the law changes the IRS may issue Temporary
Regulations to offer prompt guidance while a Proposed Regulation is being formulated.
Temporary Regulations are not subject to the commentary process required for Proposed
Regulations. However, they are effective immediately upon issue and carry the same
weight as a Final Regulation. Temporary Regulations remain in effect until a Final
Regulation is released. That period is limited to three years. Temporary Regulations are
published in the Federal Register and later in the Code of Federal Regulations.
Final Regulations: Still retaining the Treasury Decision designation, Final Regulations
first appear in the Federal Register. They are later codified into Title 26 of the Code of
Federal Regulations where they are no longer referred to as Treasury Decisions but
simply Regulations.
3. Understanding Regulation Citations
Once a Regulation is published in the Code of Federal Regulations, the citation to the
Regulation will look something like this: 26 C.F.R. 1.61-2(a)(1)
Understanding the meaning of the numbers that follow the abbreviation "C.F.R." is
helpful to determine whether they are applicable to your research.
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a. The Regulations are arranged in chapters. The chapter number is the number
that precedes the decimal point. Commonly encountered Regulations include:
Chapter 1: Income Tax
Chapter 20: Estate Tax
Chapter 25: Gift Tax
Chapter 31: Employment Tax
Chapter 301: Procedure and Administration
Chapter 601: IRS Procedural Rules
b. The number that immediately follows the decimal point is the governing Code
section.
c. The number that follows the dash indicates the sequence of the Re gulation and
particular subsections.
Thus, we know that the above Regulation is an Income Tax Regulation interpreting IRC
§61 and is the second Regulation issued for this Code section.
4. Access
In addition to the Federal Register and the Code of Federal Regulations, Regulations can
be found in these important sources:
The Internal Revenue Bulletin and the Cumulative Bulletin (KF6282.A2I495): This can
be compared to and is referred to as the IRS's Federal Register. It is the official, weekly
publication of the IRS and serves as notice to the world for changes in the law and new
law. Once a Regulation becomes final, it is published in the Internal Revenue Bulletin as
a Treasury Decision. Temporary Regulations are also published in this source but not
Proposed Regulations. Twice a year, the Internal Revenue Bulletin is reissued in two
bound volumes called, the Cumulative Bulletin.
The Looseleaf Services: The text of Proposed, Temporary and Final Regulations are an
important part of the tax services. Since the services are updated weekly, this is the best
place to find all current regulatory issuances associated with a tax provision in one
convenient location.
B. Revenue Rulings
1. Authority
Another interpretive tool, Revenue Rulings constitute the official position of the IRS on
the application of the Code and Regulations to specific factual situations. They are not
issued as a result of an adversarial proceeding and do not constitute primary authority. If,
however, the facts in question match those of the Revenue Ruling, then the interpretation
will likely apply equally. It is helpful to keep in mind that IRS personnel regard the
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Code, Regulations, Revenue Rulings and acquiesced Tax Court decisions as the official
policy of the IRS. IRS agents may often be more persuaded by a Revenue Ruling that
case from a District Court.
Revenue Rulings are often modified or replaced when the law changes. It is important to
make sure the Revenue Ruling being used is current. Like case law, Revenue Rulings
can be "Shepardized" either with Shepard's Federal Tax Citator or the citators that
accompany the looseleaf services.
2. Access
Internal Revenue Bulletin and the Cumulative Bulletin: This is the official source of
Revenue Rulings. Citations to Revenue Rulings are cited in the looseleaf services in the
case annotation sections for each tax provision.
3. Understanding Revenue Ruling Citations
Citation to Revenue Ruling should be to the Internal Revenue Bulletin or the Cumulative
Bulletin:
Rev. Rul. 94-195, I.R.B. 1994-4 p. 10 (as published in the Internal Revenue Bulletin)
In this example, the citation reveals that this is the 195th Revenue Ruling published in
1994. "1994-4" indicates that this Revenue Ruling can be found in the 4th issue of the
Internal Revenue Bulletin for the year 1994 and can be found on page 10 of that issue.
Rev. Rul. 94-195, 1994-1 C.B. 54 (as published in the Cumulative Bulletin)
As indicated earlier, the Internal Revenue Bulletin is reissued at the end of the calendar
year in two bound volumes called the Cumulative Bulletin. The same Revenue Ruling is
cited in this example after this reissue. "1994-1" is the volume number and "54" is the
page number.
4. Revenue Procedures
Accessed and cited similarly as Revenue Rulings, Revenue Procedures are the official
position of the IRS on procedural issues in the administration and enforcement of tax
laws. They are often directed to IRS personnel or to taxpayers who must handle a matter
with the IRS and needs to understand the proper procedure to follow. Revenue
Procedures are published in the Internal Revenue Bulletin.
C. Official Internal Documents
1. Private Letter Rulings
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Taxpayers may make formal written requests to the IRS National Office asking for advise
about the tax consequences of a specific transaction. The IRS response to the taxpayer
takes the form of a Private Letter Ruling. The Ruling is applicable only to the taxpayer to
which the Ruling is directed. Private Letter Rulings cannot be used as precedent but they
are useful in an advisory capacity as an indicator of the IRS position on a specific set of
facts. Prior to 1977, Private Letter Rulings were not available for inspection. Freedom of
Information litigation in the 1970's led to the release of Private Letter Rulings. They are
available only after language that would indicate the taxpayer's identity is stripped out.
Private Letter Rulings often serve as the basis of a Revenue Ruling if the IRS deems the
issue to be of general interest.
Private Letter Rulings are not published in any official IRS publication. They are
commercially published by Commerce Clearing House. The Law Library has the CCH
version in hardcopy from 1977 to 1998 at KF6289.A353.
They are also available online through Westlaw, Lexis, CCH Tax Research Network and
BNA Tax Management Library. Private Letter Rulings issued prior to 1977 are available
only through the IRS.
Citation example: Priv. Ltr. Rul. 98-44-037 (Aug. 5, 1998)
The first two digits (98) indicate the year. The second two digits indicate the week. The
last three digits indicate the sequence of the Rulings. So in this example, we know that
this Ruling was released in the 44th week of the year 1998 and is the 37th Ruling issue
that week.
2. Technical Advice Memoranda, General Counsel Memoranda and Determination
Letters
The IRS publishes a variety of notices, announcements and other advisory documents.
Most are not published in the Internal Revenue Bulletin but may be found online and in
print in Tax Notes (KF6262.T39 -- see p.14 of this guide for a description of this source)
and in current awareness services such as Daily Tax Report. Below is brief description of
three types of internal documents commonly encountered:
Technical Advise Memoranda : Issued by the National Office, TAMs are similar in
nature and citation to Private Letter Rulings. However, TAMs address a completed
transaction and are typically requested by IRS agent during an audit after the question
remains unanswered by the local office.
General Counsel Memoranda : Issued by the IRS Chief Counsel's Office, GCMs are
memos that review and analyze Revenue Rulings, Private Letter Ruling and TAMs.
Determination Letters : Similar in form and purpose to a Private Letter Ruling,
Determinatio n Letters are issued by a local IRS District Director rather than by the
National Office.
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IV. Case Law
A. Tax Court of the United States
1. Composition and Jurisdiction of the Court
Tax Court is a specialized court that only hears tax cases. It is composed of 19 judges
appointed by the President for 15-year terms. The court is established pursuant to §7441
if the IRC. From 1924 to 1942 the Court was the Board of Tax Appeals (BTA). It was
an administrative board of Treasury Department. In 1943 the BTA became the Tax
Court, an administrative court. In 1969, the Tax Court became a judicial court, separate
from the Treasury Department. The Tax Court has national jurisdiction and travels
around the country to hear cases. Typically, a case is presided over by one judge. Tax
Court judges are tax specialists coming to the Court with years of tax practice expertise.
Thus, if a case involves a technical issue, Tax Court is likely the best trial court forum.
Tax Court judges must apply the law that governs in the jurisdiction they are hearing the
case. If there is disagreement in the Circuit Courts of Appeal on an issue, the Tax Court
may decide a case one way in one Circuit and another way in another Circuit. Appeals
from Tax Court go to the Circuit Court of Appeals for the state where the case was heard.
Taxpayers do not have to pay the disputed tax until the Tax Court makes a decision.
2. Types of Opinions
Tax Court issues two types of opinions:
Regular Opinions: Cases that present new or unusual issues are decided through regular
opinions.
Memorandum Opinions: If the case involves the application of existing law that has
generally been resolved or involves a factual interpretation, the opinion will be issued as
a memorandum opinion. The y are usually shorter in length than regular opinions but
should not be overlooked simply because of their memo status.
3. Acquiescence and Non-Acquiescence of Tax Court Decisions
When the IRS loses in a regular decision before the Tax Court, the Commissioner may
acquiesce or nonaquiesce to the decision. In an acquiescence, the Commissioner goes on
the record as agreeing with the outcome of the case and will handle subsequent disputes
in a manner consistent with the opinion. In a nonacquiescence, notice is given that
similar disputes in the future will continue to be contested by the IRS. Acquiescences
and nonacquiescences are published in the Internal Revenue Bulletin and later in the
Cumulative Bulletin. In addition, use of a citator such as those that accompany the tax
looseleaf services or Shepard's Federal Tax Citator will reveal whether a Tax Court
ruling has been acquiesced to or not by the IRS. No other type of case gets this treatment
from the IRS including Tax Court memo decisions.
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4. Reporters for Regular Opinions
a. Official: 1924 - 1942
United States Board of Tax Appeals Reports (B.T.A.)
KF6280.A2T37
Citation example: Vertex Inv. Co. v. Comm'r, 47 B.T.A. 252 (1942).
1943 - present
United States Tax Court Reports (T.C.)
KF6280.A2T37
Citation example: Nordtvedt v. Comm'r, 116 T.C. 165 (2001).
b. Unofficial: If the case is too recent to be in the official reporter or its advance
sheets, cite to one of the two unofficial sources:
CCH Tax Court Reporter
KF6285.T35
Citation example: Haas & Assoc. Accountancy Co. v. Comm'r, [Current
Regular Decision] Tax Ct. Rep. (CCH) Dec. 54,447 (Aug. 10, 2001).
5. Reporters for Memorandum Opinions : There is no official reporter for Memo
Decisions. Cite to one of the following:
a. CCH Tax Court Memorandum Decisions
KF6285.T352
Citation example: Baldwin v. Comm'r, 80 T.C.M. (CCH) 431, Dec.
54,065(M) (2000).
Advance Sheets for the current year are in:
CCH Tax Court Reporter
KF6285.T35
Citation example: Smith v. Comm'r, [Current Memo Decisions] Tax Ct.
Rep. (CCH) (80 T.C.M.) Dec. 54,602(M) (Jan 2, 2002).
b. RIA T.C. Memorandum Decisions
KF6285.U575
Citation example: Remkiewicz v. Comm'r, 2001 T.C. Memo (RIA) ¶
2001-001.
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B. United States District Court; Courts of Appeal; U.S. Supreme Court
1. Tax Cases in Federal Court
Tax litigation may also be initiated in Federal District Courts. The taxpayer must pay the
disputed tax first and sue for a refund. Judges from Federal District Courts and Courts of
Appeals are generalists, not tax specialists. Unlike the Tax Court and The Court of
Federal Claims, jury trials are available.
2. Reporters
Cases from District Courts, Circuit Courts of Appeal and the United States Supreme
Court are published in Federal Supplement, Federal Reporter and the United States
Reports respectively. It is assumed that the researcher is familiar with these federal
reporters. There are two specialized tax reporters that publish only the tax cases from all
federal courts except Tax Court:
a. CCH United States Tax Cases
KF6285.S672
Citation example: United States v. Ristovski, 211 F.3d 127, 2000-1 U.S.T.C.
(CCH) ¶ 50, 409 (6th Cir. 2000).
b. RIA American Federal Tax Reports 2nd
KF6285.U57
Citation example: United States v. Ristovski, 211 F.3d 127, 85 A.F.T.R.2d (RIA)
2000-583 (6th Cir. 2000).
Advance Sheets for both U.S.T.C. and A.F.T.R.2d are part of their corresponding tax
services, Standard Federal Tax Reporter and United States Tax Reporter respectively.
C. United States Court of Federal Claims
1. Composition and Jurisdiction of the Court
This court was created in 1982 by the Federal Courts Improvement Act, Pub. L. 97-164.
The United States Court of Claims and the United States Court of Customs and Patent
Appeals were reorganized. The trial division of the Court of Claims became the new
United States Claims Court and the remaining divisions of both courts became the new
Court of Appeals for the Federal Circuit. In the Federal Courts Administration Act of
1992 Pub. L. 102-572, the court was renamed the United States Court of Federal Claims.
The court is composed of 16 judges. The jurisdiction of the court is national
encompassing monetary claims against the federal government. Federal Claims judges
are not tax specialists. Appeals from this Court go to Court of Appeals for the Federal
Circuit, not to the Court of Appeals for the state where the case is heard. The disputed
tax must be paid first and the taxpayer must sue the government for a refund.
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2. Reporters : There is no official reporter for the Federal Claims Court. Cite to one of
the following:
a. 1982 - 1992
Claims Court Reporter (West)
KF125.C5C532
Citation example: Ambrose v. United States, 4 Cl. Ct. 352 (1984).
b. 1992 - present
Federal Claims Reporter (West)
KF125.C5C532
Citation example: Wertz v. United States, 51 Fed. Cl. 443 (2002).
c. CCH U. S. Tax Cases
KF6285.S672
Citation example: Wertz v. United States, 2002-1 U.S.T.C. (CCH) ¶ 50,192 (Fed.
Cl. 2002).
d. RIA American Federal Tax Reports 2nd
KF6285.U57
Citation example: Wertz v. United States, 89 A.F.T.R.2d (RIA) 2002-491 (Fed.
Cl. 2002).
V. Subject-Oriented Treatises
As noted in sectio n I of this guide, the tax looseleaf services take a code-oriented
approach. While it is always important to identify the applicable code section to any
research problem, a subject approach may be appropriate for some projects. The
following bibliography lists some of the major subject treaties and their location in the
library. All of the treatises listed are kept current through pocket parts, supplements or
looseleaf updates.
A. Comprehensive Treatises
Federal Tax Coordinator, New York : Research Institute of America (1977). Logically
organized thus easy to use even by the non-tax specialist, this subject-oriented treatise
provides in-depth analysis of all tax areas with practical advise, cautions and
recommendations. Also includes the IRC, temporary and final regulations, court rules
and tax treaties.
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Boris I. Bittker & Lawrence Lokken, Federal Taxation of Income, Estates & Gifts,
Boston : Warren, Gorham & Lamont (3rd ed. 1999). 5 vols. KF6289.B58
Bittker is a highly respected tax scholar and this work is one of the leading treatises on
taxation. Provides an in-depth analysis of the taxation of individuals, businesses, estates
and gifts.
Jacob Mertens, The Law of Federal Income Taxation, St. Paul, Minn : West Group
(1954). 20 vols. KF6365.M4
Originally written by Jacob Mertens in 1954, it kept up-to-date by the publisher's
editorial staff. A very comprehensive commentary source and regarded by some as
important as the tax looseleaf services. It shares some of the same qualities. In addition
to the treatise, it includes the IRC, Code commentary, Regulations and Rulings. This is
the best source for Regulation Preambles, which are the explanatory text that
accompanies Proposed and Final Regulations justifying the promulgation of the
Regula tion.
Rabkin & Johnson, Federal Income, Gift & Estate Taxation, New York : Matthew
Bender & Co. (1942). 15 vols. KF6335.R284
This 15 volume treatise was originally written in 1942 and stands as one of the leading
comprehensive treatises on federal taxation. This treatise contains many useful practice
aids such as tax tables, checklists and tax calendars. Notably, 6 volumes of this treatise
are devoted to legislative history with many reports reprinted in full.
RIA Analysis of Federal Taxes: Income, Boston : RIA Group. 14 vols. KF6365.R5
From the publisher of the major tax looseleaf service, United States Tax Reporter, this is
RIA's comprehensive commentary source.
Tax Management Portfolios, Washington D.C. : Bureau of National Affairs. Over 300
individual portfolios. KF6289.A1T35
Each portfolio analyzes a specific tax issue for income taxation, estate and gift taxation
and foreign income. An excellent starting point. If a portfolio is available for your topic,
it will provide an overview of the law and citations to primary materials. Published by
Bureau of National Affairs.
Tax Notes, Washington D.C. : Tax Analysts. KF6272.T39
This source is a weekly periodical, not a treatise. However, it merits inclusion in this
section due to its comprehe nsive and timely coverage of current IRS actions,
Congressional action including new bills, hearings and reports, review of court cases and
text of many IRS releases such as Announcements, Delegation Orders and Notices not
available in any other publicatio n. A cumulative annual index is issued at the end of each
year.
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B. Subject-Specific Treatises
1. Accounting
Stephen F. Gertzman, Federal Tax Accounting, Boston : Warren, Gorham & Lamont (2d
ed. 1993). 1 vol. KF6450.G47
2. Banks
Lance W. Rook, Federal Income Taxation of Banks & Financial Institutions, Boston :
Warren, Gorham & Lamont (6th ed. 1990). 1 vol. KF6495.B2F42
3. Bankruptcy
C. Richard McQueen & Jack F. Williams, Tax Aspects of Bankruptcy Law & Practice, St.
Paul : West Group (3rd ed. 1997). 1 vol. KF6332.M352
4. Business Organizations
Boris I. Bittker & James S. Eustice, Federal Income Taxation of Corporations and
Shareholders, Boston : Warren, Gorham & Lamont (7th ed. 2000). 1 vol. KF6464.B5
William R. Christian & Irving M. Grant, Subchapter S Taxation, Boston : Warren,
Gorham & Lamont (4th ed. 1998). 1 vol. KF6491.G7
James S. Eustice & Joel D. Kuntz, Federal Income Taxation of S Corporations, Boston :
Warren, Gorham & Lamont (4th ed. 2001) 1 vol. KF6491.E84
Bruce R. Hopkins, The Law of Tax-Exempt Organizations, New York : Wiley (6th ed.
1992) 1 vol. KF6449.H6
William S. McKee, Federal Taxation of Partnerships & Partners, Boston : Warren,
Gorham & Lamont (3rd ed. 1997). 2 vols. KF 6452.M35
Arthur B. Willis et al, Partnership Taxation, Boston : Warren Gorham & Lamont (6th ed.
1997). 2 vols. KF6452.W553
5. Consolidated Returns
Jack Crestol et al, The Consolidated Tax Return, Boston : Warren, Gorham & Lamont
(5th ed. 1993). 1 vol. KF6499.C58C68
6. Divorce
Leon Gabinet & Harold G. Wren, Tax Aspects of Marital Dissolution, St. Paul : West
Group (2d ed. 1997). 1 vol. KF6333.W74
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Marjorie O'Connell, Divorce Taxation, Boston : RIA Group (1982). 1 vol.
KF6335.A6O36
7. E-Commerce
David E. Hardesty, Electronic Commerce: Taxation and Planning, Boston : Warren,
Gorham & Lamont (1999). 1 vol. KF6495.C57H37
8. Estate Planning
A. James Casner & Jeffrey N. Pennell, Estate Planning, New York : Aspen Law &
Business (6th ed. 1998). 3 vols. KF749.C33
James W. Colliton, Charitable Gifts, Boston : Warren, Gorham & Lamont (3rd ed. 1998).
1 vol. KF6388.C65
Frederick K. Hoops & Frederick H. Hoops III, Family Estate Planning Guide, St. Paul :
West Group (4th ed. 1994). 2 vols. KF750.H63
Edward F. Koren, Estate & Personal Financial Planning, St. Paul : West Group (1988).
5 vols. KF6297.E87
Estate Planning & Taxation Coordinator, New York : RIA Group (1978). 7 vols.
KF6285.U55
David Westfall & George P. Mair, Estate Planning Law & Taxation, Boston : Warren,
Gorham & Lamont (3rd ed. 1994). 1 vol. KF6584.W47
Howard M. Zaritsky & Stephen R. Leimberg, Tax Planning with Life Insurance, Boston :
Warren Gorham & Lamont (2d ed. 1998). 1 vol. KF6428.L5Z37
9. Fraud
Darrell McGowen, et al, Criminal Tax Fraud, Lexis Law Publishing, (2d ed. 1994). 3
vols. KF6334.M34
10. Gifts, Estates and Trusts
Regis W. Campfield, Fiduciary Tax Guide, Chicago : Commerce Clearing House (1990).
1 vol. KF6571.A8C25
Norman H. Lane & Howard M. Zaritsky, Federal Income Taxation of Estates and Trusts,
Boston : Warren, Gorham & Lamont (3rd ed. 2001). 1 vol. KF6443.L35
Walter L. Nossaman & Joseph L. Wyatt Jr., Trust Administration & Taxation, New York
: Matthew Bender & Co. (Rev. 2d ed. 1966). 4 vols. KF6443.N6
15
RIA Analysis of Federal Taxes: Estate & Gift, New York : RIA Group (1991). 2 vols.
KF6571.A8R5
Charles E. Rounds, Loring : A Trustee's Handbook, New York : Aspen Law & Business
2002) 1 vol. KF730.L6
Richard B. Stephens, et al, Federal Estate and Gift Taxation : Including the GenerationSkipping Transfer Tax, (Boston : Warren, Gorham & Lamont 1997). 1 vol. KF6572.S7
11. Individuals
Boris I. Bittker & Martin J. McMahon, Federal Taxation of Individuals, Boston : Warren,
Gorham & Lamont (2d ed. 1995). 1 vol. KF6369.B57
12. International Taxation
CCH Tax Treaties, Chicago : Commerce Clearing House. 4 vols. KF6306.U5
Joseph Isenbergh, U.S. Taxation of Foreign Persons & Foreign Income, New York :
Aspen Law & Business (3rd ed. 2002). 4 vols. KF6441.I8
Joel D. Kuntz & Robert J. Peroni, U.S. International Taxation, Boston : Warren, Gorham
& Lamont (1992). 3 vols. KF6419.K86
Rufus von Thulen Rhoades & Marshall J. Langer, U.S. International Taxation & Tax
Treaties, New York : Matthew Bender & Co. (1996). 6 vols. KF6306.R48
13. Inventories
Leslie J. Schneider, Federal Income Taxation of Inventories, New York : Matthew
Bender & Co. (1979). 3 vols. KF6450.S3
14. Practice & Procedure
Michael I. Saltzman, IRS Practice & Procedure, Boston : Warren, Gorham & Lamont
(2d ed. 1991). KF6301.S25
15. Securities
Martin L. Fried, Taxation of Securities Transactions, New York : Matthew Bender & Co.
(1998). 2 vols. KF6415.F75
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16. State Taxation
CCH State Tax Guide, Chicago : Commerce Clearing House (1959). 3 vols.
KF6750.A6C6
CCH State Tax Reporters: All States, Chicago : Commerce Clearing House (1959).
13 vols.KF6750.A6C66
Jerome R. Hellerstein, State Taxation, Boston : Warren, Gorham & Lamont (2d ed.
1993). 2 vols. KF6750.H442
RIA State & Local Taxes: All States Tax Guide, Boston : RIA Group (1990). 2 vols.
KF6750.A6A44
State Tax Notes, Washington D.C. : Tax Analysts. KF6750.S735
Tax Management Multistate Tax Portfolios, Washington D.C. : Bureau of National
Affairs (1994). 61 portfolios KF6750.A6T3
VI. Journals
Journal literature can provide useful research information especially in areas of tax law
that are new or developing. Journals are also useful for current awareness. Standard
journal indexes such as Legal Trac and Index to Legal Periodicals are the best means of
access to legal journal articles. The following list is a selection of titles of journals
devoted to tax law issues:
Akron Tax Journal
The Practical Tax Lawyer
Florida Tax Review
Practical Tax Strategies
The International Tax Journal
Real Estate Taxation
Journal of Corporate Taxation
The Tax Advisor
Journal of International Taxation
Tax Law Review
Journal of Multistate Taxation and
Incentives
Tax Management Estates,
Gifts and Trust Journal
Journal of Real Estate Taxation
Tax Management
International Journal
The Journal of Taxation
Taxes
The Journal of Taxation of Exempt
Organizations
Virginia Tax Review
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