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Chapter 6

Copyright ©2006 Thomson South-Western, Mason, Ohio

William A. Raabe, Gerald E. Whittenburg, &

Debra L. Sanders

Tax Services and Periodicals

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Annotated Tax Services

• Sometimes called “Compilations”• Organized by Code section• Contain

– The editor’s explanation of the Code section– Recent committee reports– Treasury Regulations– Annotations of related court cases &

administrative rulings

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Topical Tax Services

• Organized by subject matter– Integrates Code & primary sources with the

secondary sources & editorial commentary

• Topics covered, type & depth of analysis vary by service

• Variety of indexes & finding tables

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Electronic Tax Services

• The tax services on the internet update the material daily or continuously

• The subscription services (i.e., RIA, CCH, BNA, etc.) are more comprehensive

• The free internet services provide only basic research ability

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Approaching the Research Problem

• Formulate the question• Other issues will likely be identified during the

research process• The initial questions may change and new

questions formed

• Choose relevant key words to begin the search in the tax services

• Judgment is required in most tax decisions because the law is often imprecise

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Approaching the Research Problem

Read the primary documents which are the authoritative sources– Do not rely solely on the annotations

(summaries) to form a decision• Annotations are the editors’ explanations• Annotations cannot be cited, only the primary

(original) sources can be cited in tax research

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Accessing Electronic Tax Information

• Understand which database should be used and how to enter keywords or terms

• Present search results in order of relevance or by database sources

• Begin with editorial material if unfamiliar with topic– Usually has hyperlinks to primary authority

• Identify relevant authority• Check authority with citator• Carefully read and evaluate authority• Ascertain optimum treatment for item in question

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RIA Checkpoint

• Internet tax service– Full range of products (databases) available

• All primary authority (Code, Regs, Cases, etc.)• Federal Tax Coordinator 2d• United States Tax Reports• Citator 2nd Series• WG&L journals and textbooks• IRS publications

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RIA Checkpoint Opening Screen

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RIA Checkpoint

• Be sure to limit the search only to those databases pertinent to the research question– If not limited, too many irrelevant documents

may be retrieved

• Three ways to initiate a search:– Keyword search– Cite search– Contents search

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RIA - Keyword Search

• Three steps:1. Enter your keywords in the search box2. Select one or more databases3. Click “Search”

• Be sure to identify the “best” keywords– This comes with experience

• Try to limit the retrieved documents to those relevant to your tax question by:

• Refining the search keywords and terms used• Selecting more databases• Unselecting databases no longer relevant• Using additional search options (see next slide)

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RIA - Keyword Search:Search Options

• Boolean Connectors– Use to select the order of the keywords– Search for phrases– Set proximity searching– See next slide for RIA’s Boolean connectors

• Thesaurus can be applied to key words

• Can choose from recent key word searches

• Date restrictions can be applied

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RIA Checkpoint Boolean Connectors

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RIA - Contents Search

• Use computerized tax services same way as published (paper) services

• Two Methods:1. Table of contents search

• Similar to scanning binders of published services

2. Index search• Alphabetical search by topic

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RIA - Contents Search

• Table of Contents (TOC) Search– Click on the TOC– Click on the relevant topic– Keep clicking to “drill down” through the TOC

to find a document– Very effective if the researcher knows where

the relevant material can be found– A keyword search can easily be performed– See a TOC example on next slide

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RIA Checkpoint Federal Tax Coordinator 2nd Table of Contents

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RIA - Contents Search

• Index search– Federal Indexes contains an index for each

database:• Federal Tax Coordinator 2d Topic Index• Code Arranged Annotations & Explanations (USTR)

Topic Index• RIA’s Federal Tax Handbook Topic Index• Return Guide Indexes• Current Code Topic Index• Final & Temporary Regulations Topic Index• Proposed Regulations Topic Index

– May also perform a keyword search on indexes• Similar to TOC keyword search, but restricted to the

index entries

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RIA - Cite search

• Citation Search can be used if you know the document needed

• Types of Documents Available in Cite Search:– Code & Regulations– Code History– Cases (AFTR 2d, TC, TC Memo, etc.)– Revenue Rulings, Private Letter Rulings, IRB– IRS Publications, Circular 230– Revenue Procedures, AOD’s, TAM’s– Others

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RIA - Cite search

• Code Search– Enter Code section number– Leads to the actual Code section– Which contains leads to:

• Explanations & annotations• Links to FTC topics• Regulations & committee reports• Code History• WG&L treatises

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RIA - Cite search

• Case Search– Name of the case– The case’s citation

• Enter the citation in the templates provided

– Links to editorial material appear

• Neither the Cite nor Code search will likely pull up ALL relevant documents related to an issue

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CCH Tax Research NetWork

• Internet tax service– Similar to RIA with a full range of products

available including:• Research Consultant (topical service )• Standard Federal Tax Service (annotated

service)• and Master Tax Guide

• Searches available:– Keyword search– Cite and contents search

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CCH Tax Research Network Federal Opening Screen

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CCH Search Options

• Keyword search– Allows search by all terms (default), any term,

exact phrase, Boolean connectors, dates– Documents retrieved:

• Are sorted by relevance (default)• Researcher may select other sorting methods

– Thesaurus applied to key words (default)

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CCH Search Options

• Cite and Contents Search– Citation search

• May use Code section or other primary source citations such as cases, rulings, regs, etc.

– Cannot cite search by case name

• Results link to editorial material

– Table of Contents Search• “Drill down” is similar to RIA

– Index Search• Topical index database contains an index for

several databases

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Tax Periodicals

• Tax articles are very useful to– Learn new approaches to a tax problem– Look for guidance in solving complex tax

problems– Read about new tax law

• Well-written articles cite the original tax sources a tax researcher can use

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Tax Periodicals

Citing articles in professional tax research is limited to two situations:(1) if the researcher is referring to the author’s

analysis and conclusions as stated in an article; or

(2) if the researcher cannot find any controlling primary sources of law and a secondary source addresses the issues.

• Tax articles are now being cited more frequently in case opinions than in the past.

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Tax Periodicals: Citation

Standard form to cite a printed tax article:

Acceptable form of citing an internet tax article:

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Tax Periodicals

• Types of Periodicals– Annual proceedings from conferences– Scholarly reviews:

• Law reviews• Academic journals

– Professional journals– Newsletters

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Tax PeriodicalsSelected Tax Newsletters