Federal Tax Research: Judicial Opinions

Below are links to the pages located under the tab, "Judicial Opinions."

• Online Collections of Tax Case Law
• Tax Case Law Reporters (Online &Print)
• Citation & Abbreviation of Tax Case Law
• Tax Court: Memorandum Decisions
• Tax Court: Tax Court Decisions (Regular, Memorandum, Summary)
• Board of Tax Appeals Decisions

Below are links to sources offering instruction on case law research.

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:

• Formally published decisions: Also called TC Opinions or "division opinions." They are published in the Tax Court Reports.
• Memorandum decisions:  Also called TC Memos or Memo Opinions: They are unpublished decisions, generally involving settled legal issues. They are still often cited though. and
• Summary decisions These decisins involve controversies of below $50,000. They are not precedential.

"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 § 4.10.7.2.9.1)

Fore more information, see McDermott's very helpful Types of Tax Court Opinions and Their Precedential Effect

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.