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Research Guides

Tax Law

Tax Citators

Citators are used to determine the subsequent history of a case, statute, or regulation, and thus assess its validity.  While it is perfectly acceptable to use a general citator such as Shepard's (Lexis Advance) or KeyCite (Westlaw), there are specialized citators for federal tax research.

Judicial Authority

Income tax litigation begins in one of three forums. If the taxpayer has not paid the tax, the forum is the United States Tax Court. In this forum, there is no right to a jury trial, but the judges have more tax expertise and sophistication due to the specialized nature of the court. If the taxpayer has paid the disputed tax and is then refused a refund, the forum is either the federal district court (where the taxpayer is entitled to a jury trial) or the Court of Federal Claims.
 
Appeals from Tax Court and federal district court decisions are to the Circuit Court of Appeals covering the taxpayer's state of residence. Appeals from the Court of Federal Claims are to the United States Court of Appeals for the Federal Circuit.

Tax Court Opinions

The U.S. Tax Court issues three types of decisions.

Tax Opinions of the Federal District and Appellate Courts

Reported tax decisions of the district courts, Court of Federal Claims, and the Circuit Courts of Appeal are printed in the reporter applicable to that court, just like any other opinion.

Both reported and "unreported" tax decisions from these courts are also printed in two commercial print reporters: United States Tax Cases (U.S.T.C.) and American Federal Tax Reports (A.F.T.R.). U.S.T.C. is published by CCH, and A.F.T.R. is published by Thomson Reuters (formerly RIA). Each reporter integrates with the applicable publisher's print and electronic finding aids (CCH's Standard Federal Tax Reporter and Cheetah; Thomson Reuters's United States Tax Reporter and Federal Tax Coordinator).