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Federal Tax Research: IRS Documents

A guide to conducting federal tax research

Overview of IRS Documents Research

These materials can help you get started. Remember that IRS documents are not as authoritative as regulations.

Understanding IRS Guidance: A Brief Primer is available on the IRS website.

Tina R. Green & Nikki L. Laing, IRS Alphabet Soup: Practical and Precedential Value of AODs, IRBs, TAMs and Other Guidance, 15 J. TAX PRAC. & PROC. 27 (2013). (Available on HeinOnline.)

Collections of IRS Documents

There are several collections of IRS Documents online:

Administrative Decisions and Guidelines, Internal Revenue Service from Westlaw

IRS Documents on Bloomberg

On VitalLaw, go to Primary Sources within the Tax collection. IRS Administrative Rulings and Positions is in the dropdown menu.

Internal Revenue Bulletin

The Internal Revenue Bulletin is published weekly, and a Cumulative Bulletin is published semi-annually.

Types of documents that may be published in the Internal Revenue Bulletin ("IRB") include:

  • Announcements
  • Actions on decisions/notices of acquiescence
  • Committee Reports
  • Notices
  • Proposed & final regulations
  • Treasury decisions
  • Revenue rulings
  • Revenue procedures

The Internal Review Bulletin is available on the IRS website; cumulative bulletins are available on LexisWestlaw, and HeinOnline from 1919-2008, and 2008 to the present.)

IRS Publications

The following are also important IRS publications. They are published in the Internal Revenue Bulletin. All of the descriptions are on the IRS Website in Understanding IRS Guidance: A Brief Primer or Internal Revenue Manuals: Part 4, Examining Process.

Revenue Rulings - "A revenue ruling is an official interpretation by the IRS of the Internal Revenue Code, related statutes, tax treaties and regulations. It is the conclusion of the IRS on how the law is applied to a specific set of facts."

Revenue Procedures - "A revenue procedure is an official statement of a procedure that affects the rights or duties of taxpayers or other members of the public under the Internal Revenue Code, related statutes, tax treaties and regulations and that should be a matter of public knowledge." 

Notices - "A notice is a public pronouncement that may contain guidance that involves substantive interpretations of the Internal Revenue Code or other provisions of the law." 

Announcements - "Announcements are public pronouncements on matters of general interest, such as effective dates of temporary regulations, clarification of rulings and form instructions. They are issued when guidance of a substantive or procedural nature is needed quickly." "An announcement is a public pronouncement that has only immediate or short-term value."

Publications - "IRS Publications explain the law in plain language for taxpayers and their advisors. They typically highlight changes in the law, provide examples illustrating IRS positions, and include worksheets."

Technical Advice Memoranda - "A technical advice memorandum, or TAM, is guidance furnished by the Office of Chief Counsel upon the request of an IRS director or an area director, appeals, in response to technical or procedural questions that develop during a proceeding. A request for a TAM generally stems from an examination of a taxpayer's return, a consideration of a taxpayer's claim for a refund or credit, or any other matter involving a specific taxpayer under the jurisdiction of the territory manager or the area director, appeals."

General Counsel Memoranda - "General Counsel Memoranda (GCM) are legal memoranda from the Office of Chief Counsel prepared in connection with the review of certain proposed rulings (Rev. Ruls., PLRs, TCMs). They contain legal analyses of substantive issues and can be helpful in understanding the reasoning behind a particular ruling and the IRS’ response to similar issues in the future."

Actions on Decisions - "It is the policy of the IRS to announce at an early date whether it will follow the holdings of lower courts in certain cases. An Action on Decision (AOD) is the document making such an announcement...The recommendation in every AOD is summarized as acquiescence, acquiescence in result only, or nonacquiescence."

  • "Acquiescence" indicates neither approval nor disapproval of the reasons assigned by the court for its conclusions.
  • "Acquiescence in result only" indicates disagreement or concern with some or all of those reasons.
  • "Nonacquiescence" signifies that, although no further review was sought, the IRS does not agree with the holding of the court and generally, will not follow the decision in disposing of cases involving other taxpayers. In reference to an opinion of a circuit court of appeals, a nonacquiescence indicates that the IRS will not follow the holding on a nationwide basis. However, the IRS will recognize the precedential impact of the opinion on cases arising within the venue of the deciding circuit.

Finding IRS Publications

You can find IRS Publications on:

  • Bloomberg (under "Advanced Search," choose the type of document you want under "Primary Sources")
  • TaxNotes (click IRS Guidance on the main screen)
  • VitalLaw (Tax(Federal) > Primary Sources. Choose "IRS Administrative Rulings and Positions" from the drop-down menu. Clicking the blue box that says "see all" will give you access.
  • Westlaw (Administrative Decisions & Guidance > Federal Administrative Decisions & Guidance > Department of the Treasury

You will need a password to access these sites.