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Legal Citations: Hierarchy of Tax Materials

Hierarchy Of Authority For Tax Materials Listed In Descending Order Of Precedence

1.       Internal Revenue Code (IRC) / United States Code (USC)

2.       Treasury Regulations (Treas.Reg.) / Code of Federal Regulations (CFR)

3.       U.S. Supreme Court (U.S. or L.Ed. or S.Ct.)

4.       U.S. Circuit Courts of Appeals (F. or F.2d.).  11 numbered by circuit; 13 total. 
(Wisconsin is in the Seventh Circuit; the Seventh Circuit Court of Appeals is located in Chicago.)

5.       Federal courts of original jurisdiction (decisions may be appealed to a Circuit Court of Appeals):

A.      U.S. District Courts (cited as F. Supp.)

Federal District Court decisions will vary on a particular topic since each court decision is rendered by a separate, geographically-bound court.  94 districts nationwide.  (La Crosse is in the Western District of Wisconsin.  The U.S. District Court--Western District of Wisconsin is located in Madison.)

B.      U.S. Tax Court

The tax court is a national court and will only follow the decision of the Circuit Court in which the taxpayer is domiciled. As a result, Tax Court decisions are not necessarily consistent on a particular topic. Tax court decisions are classified as follows:

I.        Regular decisions rendered on particular topics which are still unsettled or controversial.  Decisions may be made by one judge or reviewed by the entire court.  (cited as TC since 1942; BTA before 1942)

II.     Memorandum decisions, generally made by one judge, are also primary authority but on less controversial, settled issues. (cited as TCM)

C.      U.S. Court of Federal Claims (cited as FedCl since 1992; ClCt from 1982-1992; CtCl before 1982)
National court that handles all types of claims against the U.S. government, including those in the tax area.

7.       Revenue Rulings (cited as Rev. Rul.)

Issued by the IRS, establishing official IRS interpretation of the tax law for specific types of transactions.  Binding for the IRS for future tax treatment of such  transactions.

8.       Private Letter Rulings (cited as PLR or LtrRul)

Issued by the IRS upon request to an individual taxpayer regarding tax treatment for a specific transaction being considered.