Tax Research Using the Internal Revenue Code and Treasury Regulations

Categories: Federal Tax, IRS CE
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About Course

This two-hour continuing education course provides tax professionals with a practical, systematic understanding of federal tax research — the hierarchy of primary tax authority, the categories of IRS subregulatory guidance, and the judicial precedent that shapes how tax disputes are actually resolved. The course is designed for enrolled agents and other tax return preparers who need to move beyond secondary sources to confidently locate, evaluate, and cite the primary authority that actually supports a return position or client recommendation.

Participants examine the Internal Revenue Code and each stage of Treasury Regulation finality — proposed, temporary, and final — including the 2024 Supreme Court decision in Loper Bright Enterprises v. Raimondo that eliminated Chevron deference and changed how courts review Treasury’s interpretation of ambiguous statutory language. The course provides detailed coverage of subregulatory IRS guidance and of judicial authority, including the Tax Court, the Golsen rule, and the weight given to memorandum and unpublished decisions. The course concludes with a practical research methodology and the Circular 230 authority-level standards — reasonable basis, substantial authority, and more-likely-than-not — that govern how much authority a given position actually requires.

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What Will You Learn?

  • Identify the hierarchy of primary tax authority, including the Internal Revenue Code and Treasury Regulations at each stage of finality
  • Apply the post-Loper Bright framework for the weight courts give to Treasury's interpretation of ambiguous statutory language
  • Identify the categories of subregulatory IRS guidance and the degree of reliance a practitioner may place on each
  • Apply the principles of judicial precedent in tax controversies, including stare decisis and the Golsen rule
  • Apply a systematic methodology for researching a federal tax question and documenting supporting authority
  • Apply the Circular 230 diligence standards governing the level of authority required for a given return position

Course Content

Module 1 – The Hierarchy of Primary Tax Authority — The Code and Treasury Regulations
This module covers the hierarchy of primary tax authority: the Internal Revenue Code as the statutory foundation, the distinction between legislative and interpretive Treasury Regulations, the three stages of regulatory finality, and the 2024 Supreme Court decision in Loper Bright Enterprises v. Raimondo that eliminated Chevron deference for Treasury's interpretation of ambiguous statutory language.

  • The Hierarchy of Primary Tax Authority — The Code and Treasury Regulations

Module 2 – Subregulatory IRS Guidance — Reliance and Precedential Weight
This module addresses subregulatory IRS guidance — Revenue Rulings, Revenue Procedures, Private Letter Rulings, Technical Advice Memoranda, Notices, Announcements, and Chief Counsel Advice — and the important distinction between whether a source may be cited as precedent and whether it counts as authority for the substantial authority standard.

Module 3 – Judicial Authority and Precedent
This module examines judicial authority in federal tax disputes: the Tax Court, District Courts, and the Court of Federal Claims as trial forums, the Golsen rule governing circuit-specific precedent, and the differing precedential weight of regular, memorandum, and summary Tax Court opinions.

Module 4 – Practical Tax Research Methodology and Circular 230 Standards
The final module brings the prior three modules together into a systematic tax research methodology, the Circular 230 §10.34 authority-level standards — reasonable basis, substantial authority, and more-likely-than-not — and the practical elements of well-documented, defensible tax research.

Final Assessment – Tax Research Using the Internal Revenue Code and Treasury Regulations
You have completed a comprehensive review of federal tax research methodology, covering the hierarchy of primary tax authority, subregulatory IRS guidance, judicial precedent, and a systematic research methodology aligned with Circular 230 authority-level standards. You are now prepared to demonstrate your understanding of the key concepts. The following final examination assesses your knowledge of the material covered in all four modules. A passing score of 70% is required to successfully complete the course.

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