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Accounting

General Resources

Internal Revenue Code

Title 26 of the U.S. Code contains nearly all of the federal tax laws. This title is commonly referred to as the "Internal Revenue Code" (IRC) or sometimes simply as "The Code."

The current version is the Internal Revenue Code of 1986, as amended. There have been three major enactments of the IRC: The 1939 Code, the 1954 Code, and the 1986 Code. Prior to the 1939 Code, federal tax laws were individual Revenue Acts.

Structure. The IRC is organized into subtitles, chapters, subchapters, and parts, each of which contains related provisions on a particular topic. Related sections are often cross-referenced to each other. Therefore, it is often useful to read the table of contents to the IRC or to a subchapter in order to get an overview of the structure of a topic.

Subtitles:

A Income Taxes
B Estate & Gift Taxes
C Employment Taxes
D Misc. Excise Taxes
E Alcohol & Tobacco Excise Taxes
F Procedure & Administration
G The Joint Committee on Taxation
H Financing of Presidential Campaigns
I Trust Fund Code
J Coal Industry Health Benefits
K Group Health Plan Benefits

Commonly-Researched Subchapters of Subtitle A (Income Taxes):

A Determination of Tax Liability (sections 1 - 59B)
B Computation of Taxable Income (sections 61 - 291)
C Corporate Distributions and Adjustments (Corporate Tax) (sections 301 - 385)
J Income Tax on Estates and Trusts (sections 641 - 692)
K Partners and Partnerships (Partnership Tax) (sections 701 - 777)
S "S Corporations" (sections 1361 -1379)

Definitions. Generally, each group of related sections will have a section of definitions. In addition, section 7701 contains over 50 definitions of terms that are used throughout the IRC.

Government Reports

Executive
Congressional
Board of Governors of the Federal Reserve

Case Law

There are five federal courts that have jurisdiction over disputes between taxpayers and the Government.

All tax cases are first tried in one of three lower level trial courts: the U.S. Tax CourtU.S. District Court, or U.S. Court of Federal Claims.

Tax cases tried in all of these courts are later appealed to the U.S. Courts of Appeals. Although it is a national court, the U.S. Tax Court hears cases in different locations around the country, and appeals of Tax Court cases are heard by the U.S. Court of Appeals for the Circuit in which the taxpayer resides. Appeals of cases from the U.S. District Courts are heard by the U.S. Court of Appeals for the Circuit in which they sit. Appeals from cases decided by the U.S. Court of Federal Claims are heard by the U.S. Court of Appeals for the Federal Circuit.

As with all federal cases, the court of last resort is the U.S. Supreme Court

U.S. Tax Court

The U.S. Tax Court is a specialized court that hears only federal tax cases at the trial level. Before 1943, the U.S. Tax Court was called the Board of Tax Appeals (BTA). 

Taxpayers appearing before the Tax Court are not required to pay the disputed tax amount before the case is heard (i.e., "deficiency procedure"). However, if unsuccessful, the taxpayer will owe interest on the tax liability in dispute. Jury trials are not offered. 

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

Summary decisions are issued in "small" cases, which is an expedited procedure for individual taxpayers with less than $50,000 in tax liability. Summary decisions are not appealable, and thus are not considered precedent. There is no official or unofficial reporter for summary decisions.

Think Tanks

Public policy research and analysis is often the province of non-profit research organizations known as think tanks.

Tax Policy Think Tanks:

Public Policy & Economic Policy Think Tanks: