ACCT 366 / 302 - Federal Income Tax I / Organizations & Transactions: Home

Primary sources are the legally binding source that you can cite to support your position as it relates to your fact pattern.

There are basically FIVE resources that you should be citing for your fact patterns.

1.  Internal Revenue Code ( IRC )

2.  Treasury Regulations, are all in Title 26 of the Code is assumed ( Treas. Reg. §Part Number.Section Number - SubSection Number )

3.  Court Cases ( Number, Court Abbreviation, Number )

4.  Tax Court Memorandum ( TCM )

5.  Revenue Rulings as issued by the IRS ( Rev. Rul. Year - Number )

6.  Other IRS publications, but typically these are IRS Publication #NNN, the Internal Revenue Manual or an Internal Revenue Bulletin.

If there isn't ANY primary source information, you can argue your case using salient secondary resources such as academic research or related precedent from similar situations (usually manifest in a court case).

Do NOT cite any secondary resource that is intended to help you find the appropriate primary information or offer guidance about what the primary resource means as it is not a legally binding authority. 

Inside of CCH AnswerConnect : TOPIC pages, EXPLANATION, and CURATED content are not primary resources.  While useful for context and orientation to the issue you are researching, they are not to be cited as an authority - because they are not a legally binding authority, they are CCH's interpretation of the primary resource.

Tax is nine parts law, one part accounting.

Finding the best "point of entry" into the body of tax law will help you find relevant information in an efficient and effective manner. The US Master Tax Guide and the much more thorough US Standard Federal Income Tax Reporter are both well established tools to help you find the best point of entry efficiently and effectively.   You will use both of these publications through the "suggest" and "auto-complete" functionalities within AnswerConnect.

Knowing the specific verbiage, term of art or nomenclature of the tax law (or even your particular tax sub-speciality) is important.  Until you are confident of your verbiage, make use of the suggested terms offered up by AnswerConnect and take time to explore related terms / ideas to ensure you are investigating other potentially relevant terms / code sections, etc. related to your fact pattern. 

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