Tax Looseleaf Services

Some researches and tax practitioners start legal tax research with a tax looseleaf service. The tax looseleafs are helpful because they combine the current version of the Internal Revenue Code (“IRC”) and the IRS Regulations with detailed explanations and analysis of the IRC and Regulations and case annotations.

Using Tax Looseleaf Services

(Source: Harvard University)

CCH Standard Federal Tax Reporter (SFTR)

When using the SFTR be sure to use the most recent volumes available, in this case the 2004 volumes. The SFTR is a 25-volume looseleaf service arranged by IRC section. All the entries also have assigned paragraph numbers. An entry in a compilation volume contains the full text of an IRC section and the corresponding regulations, annotations to IRS documents and judicial decisions, and editorial explanations for the IRC section. The SFTR also contains stand alone IRC volumes which contain the full text of the IRC as well as brief explanations of amendments to individual sections.

The easiest way to use the SFTR is to look up a code section in the compilation volumes (1-18) or find a paragraph number reference in the index, and then look up the corresponding entry in Volumes 1-18. The spine of each volume lists the IRC sections, paragraph numbers, and topic keywords it covers. The SFTR has a very detailed topical index located in a separate volume which refers to the paragraph numbers. If you are looking for information about a topic contained in regulations or IRS documents, you can look up the relevant citation in the Finding Lists at the rear of the Citator Volume, which will refer you to an appropriate paragraph number to look up in the compilation volumes. You must update your research by looking in Volume 19, the New Matters Volume, which includes new rulings, annotations concerning newly decided cases, and the legislative status of bills. To find recent developments, look up the paragraph number you are dealing with in the Cumulative Index in Volume 19.

The SFTR is also available online through the CCH Tax Research NetWork, accessible through the Harvard Law School Network and available at some law firms. You can search the SFTR in the Federal Tab by clicking on the reporter’s name under the heading “CCH Explanations and Analysis” and entering search terms in the Search box at the top of the page.

RIA United States Tax Reporter (USTR)

The USTR is a 36-volume looseleaf tax service arranged by IRC section, which is accessed in similar ways to the SFTR. Each entry is assigned a paragraph number, with the relevant code number corresponding to the first portion of the paragraph number. For example, IRC § 401 is discussed in paragraph numbers 4010, 4011, etc. An entry in the compilation contains the full text of the IRC section, followed by excerpts from relevant committee reports, related regulations, editorial explanations, and annotations of decisions and rulings. The USTR also contains stand-alone IRC volumes which contain the full text of the IRC as well as the complete history of every amendment to a section since 1954. The IRC volume also has a topical index to the code sections.

The easiest way to use the USTR is to look up a code section in the compilation volumes (3-15A) or find a paragraph number reference in the index, and then look up the corresponding entry in the compilation volumes. The spine of each volume lists the IRC sections, paragraph numbers, and topic keywords it covers. The USTR has a detailed, topical index in Volume 1 which points to paragraph numbers. Volume 2 contains tables of cases, rulings, and IRS pronouncements, which provide cross-references to the paragraph numbers that discuss those cases and pronouncements. You must update your research by looking in Volume 16 “Recent Developments.” Volume 16 contains a cross-reference table that cross-references the paragraph numbers to updating materials, such as cases and IRS rulings and procedures.

The USTR is also available online through Westlaw, RIA-USTR, and through RIA Checkpoint. RIA Checkpoint is accessible through the Harvard Law School Network and is available at some law firms. You can search the USTR by checking the boxes in front of the USTR entries under the “Editorial Materials” section and entering search terms in the Search box at the top of the page.

BNA Tax Management Portfolios

There about 300 different portfolios and each of them covers a narrow topic in great detail. Each portfolio contains a Detailed Analysis section with extensive footnoting, that presents and analyzes the relevant IRC section, regulations, and cases and also provides tax planning techniques. The Working Papers section contains practitioner checklists, forms, sample agreements and contract clauses. To find a portfolio, look in the looseleaf Portfolio Index. The Portfolio Index contains a subject index, a code section index, and a classification guide, which is a list of portfolios arranged by major category. The indexes and guide will point you to the portfolio number and page reference of a relevant portfolio.

If your firm has access to Tax Management Weekly Report, you should use this to update the portfolios. On its back page, an issue of Tax Management Weekly Report has a table of affected portfolios.

Citing Tax Looseleaf Services with Bluebook

• Citing CCH Standard Federal Tax Reporter (Bluebook Rule 19 and T.16): Example: Accounting Periods, [2012] 8 Stand. Fed. Tax. Rep. (CCH) ¶ 20,307, at 38,026 (Feb. 17, 2012).
• Citing RIA United States Tax Reporter (Bluebook Rule 19 and T.16): Example: Gross Income Defined, 3A U.S. Tax Rep. (RIA) ¶ 614, at 13,086 (Jan. 9, 2012).
• Citing BNA Tax Management Portfolios (Bluebook Rule 19 and T.16): Example: Deduction Limitations: General, 504-2nd Tax Mgmt. (BNA) (2002).