Topical Tax Services
Congress has sought to organize the federal tax law such that related code sections are grouped together in a relatively logical structure. Several commercial tax services are structured in a manner that is similar to this topical outline of the Code. In addition, these topical tax services divide the tax law into its functional components. In so doing, the editors have identified certain underlying principles and practices of the Code that are not apparent from an examination of a numerically sequenced listing of code section titles.
The topical tax services cut across otherwise arbitrary code section boundaries to present material that you may encounter in your research, but are found in various nonadjacent code sections. For example, the topical service might discuss, in the analysis of business expense deductions, additional sections such as §262, the disallowance of deductions for personal expenditures; and §263, the disallowance of deductions for capital expenditures. In an annotated service these additional sections would be discussed separately. A topical approach to tax law often lends itself to a smoother integration not only of functionally related (but numerically separate) code sections, but also other primary and secondary sources of the federal tax law, including court cases, administrative pronouncements, and general editorial commentary.
The typical topical tax service includes a variety of indexes and finding lists for its analytical material, for example, by key word, case name, revenue ruling, private letter ruling, and code section number. In addition, the topical services present the titles of their major divisions on the spines of the volume binders, which can serve as another means of entry into the reference materials. These indexes parallel those that are available within the annotated services. Thus, the two types of services (annotated and topical) are distinguished from each other by the structure of their material, not the structure of their indexes.
There are several topical tax services available, including ones published by Research Institute of America (RIA) and Commerce Clearing House (CCH). Other services include
RIA Topical Tax Service
The Research Institute of America topical service is called the "Federal
Tax Coordinator 2d." The titles for RIA's analysis chapters are found
on a "Table of Contents" page located at the front of every volume,
individual chapters are indicated by a capital letter. At the beginning of
every chapter, a colored tab card is followed by a fairly detailed "Table
of Topics" which indicates, by paragraph number, the tax provisions that
are discussed in the chapter. Greater detail as to the contents of the RIA
chapter is included in the "Detailed Reference Table," which immediately
follows the Table of Topics. You can scan outline of these tables to identify
the paragraph, or series of paragraphs, that may be most useful to your research.
Finally, before the paragraphs of analysis of the tax law are presented, the
service indicates, in a "Treated Elsewhere" table, other chapters
and paragraphs of the service that might be of interest. Current developments
in the applicable law are included at the end of the chapter.
Included in the discussions of the various tax provisions are "RIA Highlights."
The most frequently encountered highlights are:
Illustration: To clarify the tax rules and problems discussed, with simple easy-to-follow illustrations.
Caution: To warn of dangers which arise in particular tax situations and, where appropriate, to indicate what should be done.
Recommendation: To provide specific, carefully studied guides to action which will keep taxes at a legal minimum.
Observation: For professional analysis or commentary which is not part of cited authorities.
Bear in mind that these RIA highlights are editorial in nature, and that they do not constitute binding legal authority. You should always review the primary tax law sources.
The text of the RIA service is heavily footnoted, to disclose the primary citations for the referenced source materials. Such footnotes include citations to both primary and secondary sources of the law, including the Internal Revenue Code, court cases, and IRS publications. In addition, the RIA footnotes are used to provide you with cross-references to other paragraphs within the service.
CCH Topical Tax Service
The topical service offered by Commerce Clearing House is entitled "Tax
Transactions Library" (TTL). This series offers a transactional approach
to tax topics, multiple tax issues, spanning many Code sections are addressed
in each tax planning volume. Volumes are grouped by "categories,"
and within each category there could be as many as 8 volumes, including a
case table and a topical index. Each of these volumes covers a different subject
matter, such as "Overview," Critical Tax Issues," "Transactional
Analysis," and "Forms - Planning Aids."
The overview section describes the scope of the volume. Critical Tax Issues
identifies potential tax problems and is cross-referenced to the Transactional
Analysis sections, where the tax matter is more fully discussed. The analysis
section is footnoted to primary sources, including Code sections, court cases,
and regulations. Included at the end of the volume there is a "New Developments"
section, where law changes are cataloged by Transaction Analysis paragraph
number.