Additional Instruction on Case Law Research
Below are links to sources offering instruction on case law research.
Tax Case Law Basics
A range of courts–including the U.S. Tax Court, U.S. Ct. of Fed. Claims, U.S. district cts., and U.S. appeal cts.–adjudicate disputes involving federal taxation. So, reporters publishing the decisions of these courts will offer judicial opinions relating to federal tax issues.
The U.S. Tax Court issues three types of decisions:
- Regular decisions;
- Memorandum decisions (unpublished decisions, generally involving settled legal issues) and
- Summary decisions (involving controversies of below $50,000).
"The U.S. Board of Tax Appeals is the predecessor of the United States Tax Court. Prior to 1942, the Board of the Tax Appeals was the prepayment forum for taxpayers who wanted judicial review of the Internal Revenue Service’s determination of deficiencies in income, excess profits, and estate and gift taxes." (U.S. Board of Tax Appeals, IRM § 126.96.36.199.9.1)
U.S. Suprme Court decisions are binding on the IRS. For opinions issued against the IRS from other courts, the IRS will often issue an announcement on its position. See AODs.