Annotated Tax Services

Annotated tax services are organized by Internal Revenue Code section numbers. The Commerce Clearing House (CCH) annotated tax service is entitled the Standard Federal Tax Reporter, and the Research Institute of America (RIA) annotated tax service is entitled the United States Tax Reporter (USTR). Both of these multi-volume sets are centered on the "compilation" volumes, which provide you with an editor's explanation and evaluation of the compiled pertinent code section and its extant regulations and clarifying court cases.

To effectively use the tax service's annotated compilation volumes you should:

  1. Locate the appropriate paragraphs in the compilation volumes
  2. Skim this material to identify the most pertinent elements of the primary tax law relative to your question
  3. Carefully read those paragraphs that you have identified as the most relevant

Starting your search:

There are three primary way in which to begin your search with one of the annotated tax services, either by using a key word, code section, or case name.

Keywords -

If you are not sure which volume of the compilations to start with, each of the annotated services (CCH and RIA) provides major division headings on the spine of each volume. These major divisions will provide you with a general overview of what is covered in that particular volume. This is a good place to start if you are unfamiliar with the topic, and cannot otherwise identify pertinent keywords, court cases, or Internal Revenue Code Sections.
If you are more familiar with the topic of concern, each of the services provides indexes that will allow you to identify the relevant volume paragraphs. The CCH service provides two such indexes, the "Rapid Finder Index" and the general "Topical Index." The Rapid Finder Index is located in the front of the service's index volume and can help you locate a number of commonly encountered broad subjects within the law. Whereas the Topical Index provides you with a more in-depth breakdown of the specific topics covered under each of the keyword entries, along with the paragraph numbers where the information is located. RIA also uses a Topical Index to help you locate the relevant paragraphs in that volume. There may also be a references to Code sections and regulations, as well as sub-paragraphs that contain a listing of court cases, letter rulings, and other administrative procedures.

CCH also provides some introductory material that precedes every major division break in each volume, and can be used to orientate yourself to the contents of the paragraphs that follow. One part of this introductory material is the "tab card." The tab card summarizes the contents of that particular division. The tab card is followed by the "table of contents" for that division. The first column of the table of contents list pertinent Code sections that are addressed in the accompanying compilation volumes; subsequent columns include references to relevant regulations, topical headings, and paragraph references. CCH also includes a "correlator" which is located immediately after the division's table of contents. The correlator can provide you with additional keywords with which to conduct your search, or with specific paragraph references to already identified keywords.

RIA also includes a "tab card" for each of the major divisions in that volume, and a table of contents that follows the tab card. Divisional table of contents are arranged in ascending paragraph order so that you can easily examine the titles for the paragraph numbers that were identified in the Topical Index. It provides you with a cross reference to the topical index.

Case Name

If you happen to know of a court case that is relevant to your question you can start your search for the appropriate Code section(s) by using one of the annotated services listing of tax related court cases. CCH's listings are compiled in two volumes called "citator." The material is organized by case name, and its entries include a reference to one or more compilation paragraphs in which the cited case is mentioned.
RIA also includes a tax-case "finding list" located in Volume 2 of the service. A supplemental table of recent cases precedes the main table of cases. The "finding list" will lead you to the paragraph(s) in the United States Tax Reporter (USTR) compilations in which the listed cases are mentioned. The USTR findings list does not include formal citations or a detailed judicial history for the listed cases.

Code Section

If you know the number of the Internal Revenue Code section that is relevant to your tax question you can find the appropriate compilation this way. Both of the services (CCH and RIA) indicate the pertinent pertinent code section ranges on the spines of the compilation volumes. Code section indicators are a major part of the compilation pages. Code and regulation section numbers that correspond to the discussion in the compilation material always appear at the bottom of the pages of the CCH service, just toward the center of the internal CCH paragraph number, and the Code section number also appears at the top of the page, following the topic. Similarly, the USTR (RIA) service places the pertinent code section numbers at the upper right-hand corner of odd-numbered pages.

Once you have located the applicable Internal Revenue Code section both services (CCH and RIA) provide you with a great deal of information in the compilation volumes.. Immediately following the editor's tab card and its summary paragraph, a table of contents for the division, and the correlator discussion, the CCH service provides an analysis of the applicable Code section. The full text of each Code section is reproduced, usually followed by a few historical notes concerning the legislative evolution of the existing provision. Typically, this notation includes a reference to the citation for any underlying Committee Reports. Following these Code section materials, a similar treatment of the accompanying regulations is provided.

RIA provides similar information in their United States Tax Reporter service. USTR compilation paragraphs are tied directly to code section numbers, in specifying a compilation paragraph, a single digit (0, 1, 2 etc.) is appended to the pertinent section number. For example, ¶1620 would be the actual code text for section 162; and ¶1622 would be the regulations associated with section 162. The digit at the end of the section number helps to clarify the nature of the material contained in the reference paragraphs.

Generally, the Code and regulation materials are followed by the service's explanation for the relevant section. Often times this explanation is easier to read, and comprehend compared to the actual code section. This may be a good place to start before reading the actual text of the code section. The service's explanation of the code is followed by an editor's annotation, which is an index of court cases relevant to the current section number. The editors annotation provides you with a summary of the case along with full citations to the annotated reference. The annotation also includes information concerning Revenue Rulings and Revenue Procedures, as well as court cases, and occasional references to related compilation paragraphs.

Often, these compilations will lead you to other primary sources of tax law, such as court cases and revenue rulings, which, other than for the current year, are found in the annotated service only in summary form. In most instances you will have to refer to the appropriate court case reporter, cumulative bulletin, or private letter ruling collection. Where court cases constitute a portion of the controlling law, you should consult a citator to evaluate the status and precedential value of the case.

Each service also contains a section that is devoted to the most recent developments in tax law, including any recent changes to the Internal Revenue Code, relevant court cases, and pending legislation. This section should always be consulted before making any decisions, there may be some information that is relevant to your particular question.