ACC 6043: Tax Research

Course research guide for ACC 6043: Tax Research

Revenue Rulings

Revenue Rulings
Revenue Rulings are public administrative rulings by the Internal Revenue Service (IRS) that apply the law to particular factual situations or refer to issues not adequately addressed by the code, regulations, or case law. A revenue ruling can be relied upon as precedent by all taxpayers. Revenue rulings are published in the Internal Revenue Bulletin (IRB) which is available in CCH IntelliConnect, and RIA Checkpoint.
Internal Revenue Bulletin (IRB)
The Internal Revenue Bulletin (IRB) is the authoritative instrument for announcing official rulings and procedures of the IRS and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest.

Searching Revenue Rulings in RIA Checkpoint

RIA Checkpoint This link opens in a new window

You can access the Revenue Rulings in RIA Checkpoint by completing the following steps: RIA >> click the "Rulings/IRB" that is under "Find by Citations" or under the "Federal" that is within the "Practice Area" pull-down menu >> then type "70-474" in the Revenue Rulings box >> now you can get your search result.

Though you can find or get the Revenue Rulings full text free online, RIA Checkpoint does offer some additional, related documents even after you get the result page you want. Please notice there are four clickable buttons displayed on top of your screen when you get to the document page for Rev. Rul. 70-474 from RIA Checkpoint database. Each of these four clickable buttons has a label on it indicating what you can get more if you click on it as below:

Track It - Track new citations to this document
Annot - View related documents for annotations
FTC - View related documents for FTC (Federal Tax Coordinator)
Citator - View related documents for citator.

For instance, after you click the Citator button on that document page for Rev. Rul. 70-474, you would see a link "REVR 70-474, 1970-2 CB 34" pops up to the left bar of your screen, thus you may further click this link and even get another pop-up screen with some lines as below:

Cited favorably : Pace, Dean F. & Jocelyne S., 2010 RIA TC Memo 2010-1647 (12/13/2010)
Cases distinguished 1: Christey, Karl W. v U.S., 48 AFTR 2d 81-5798 (DC MN, 8/19/1981)

You may note a term "Cited favorably" appears before the names in the above example. And the same is true of "Cases Distinguished". For the detailed explanation for the terms used in RIA

RIA Terminology Used in the Citator

Cited favorably – “The later case or ruling is citing to an earlier case or ruling in a favorable way, or is relying on the earlier case or ruling to support a relatively minor issue in the later case or ruling.”

Distinguished – “The later case or ruling indicates why an earlier case or ruling is different from it, either on factual or legal grounds.”

Reconciled – “The later case or ruling, looking at an earlier case or ruling that a party to a later case is trying to use to support his or her position, explains why it does or does not support a particular position in the later case or ruling, Or the later case or ruling is explaining (or reconciling) what might appear to be a conflict between an earlier case or ruling and the one before it currently.”

Internal Revenue Bulletin (IRB)

The weekly Internal Revenue Bulletin (IRB) is the authoritative instrument for announcing official rulings and procedures of the IRS. It also publishes Treasury Decisions, Executive Orders, legislation, court decisions, and other items related to the Treasury and IRS. IRB is cumulated into the Cumulative Bulletin (CB) twice a year. Internal Revenue Bulletin (IRB) is:

Available from IRS Websites: 1996 to present
Available from Nexis Uni 01/01/1954 to present (IRS Cumulative Bulletin and Internal Revenue Bulletin)