Authoritative Hierarchy

Question 1

What is the foundation of all U.S. tax laws?

Answer 1

The Internal Revenue Code (IRC) is the foundation of all U.S. tax laws, enacted by Congress in Title 26 of the U.S. Code.

Question 2

How are changes to tax law enacted?

Answer 2

Changes to tax law are passed through a tax bill that Congress approves, and the President signs into law.

Question 3

How are tax laws cited?

Answer 3

Tax laws are often cited as ‘Sec.’ or ‘§’ followed by a section number (e.g., §6695).

Question 4

What are Treasury Regulations?

Answer 4

Treasury Regulations are issued by the U.S. Treasury Department to provide official guidance on interpreting the IRC.

Question 5

What forms do Treasury Regulations come in?

Answer 5

Regulations are published in the Federal Register in one of three forms: Proposed Regulations, Final Regulations, and Temporary Regulations.

Question 6

What are Revenue Rulings?

Answer 6

Revenue Rulings are official IRS interpretations of the tax code, tax treaties, and regulations.

Question 7

Where are Revenue Rulings published?

Answer 7

Revenue Rulings are published in the Internal Revenue Bulletin (IRB).

Question 8

What are Revenue Procedures?

Answer 8

Revenue Procedures are IRS instructions on procedures for filing returns, deductions, or compliance.

Question 9

What is case law in tax law?

Answer 9

Case law develops when courts interpret tax laws, and a court’s decision can be used as precedent for similar cases in the future.

Question 10

What does IRS acquiescence mean?

Answer 10

If the IRS agrees with a court ruling, they publish their acceptance as ‘acquiescence (acq.)’ in the IRB.

Question 11

What are IRS Notices?

Answer 11

IRS Notices are public statements that provide temporary guidance on tax law or upcoming regulations.

Question 12

What are Private Letter Rulings (PLRs)?

Answer 12

PLRs are written guidance from the IRS for specific taxpayers about their unique tax situations.

Question 13

What are Technical Advice Memorandums (TAMs)?

Answer 13

TAMs are IRS guidance for specific issues during a taxpayer audit or appeals process.

Question 14

What is Treasury Department Circular 230?

Answer 14

Circular 230 sets rules for tax professionals (e.g., attorneys, CPAs, enrolled agents) practicing before the IRS.

Question 15

What is the Internal Revenue Bulletin (IRB)?

Answer 15

The IRB is the official publication for IRS rulings, procedures, Treasury decisions, court cases, and tax law updates.

Question 16

What is the Internal Revenue Manual (IRM)?

Answer 16

The IRM is the IRS’s official internal guide for policies, procedures, and authority.

Question 17

What is the summary of the hierarchy of tax law sources?

Answer 17

1. Internal Revenue Code (IRC) – Foundation of tax law.
2. Treasury Regulations – IRS’s official interpretation of the IRC.
3. Revenue Rulings and Procedures – Provide guidance on applying tax laws.
4. Case Law – Court decisions that set precedent.
5. IRS Notices, PLRs, and TAMs – Specific, non-binding guidance.
6. Circular 230, IRB, and IRM – Resources for professionals and IRS operations.