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Research method / Citation field guide

Read the citation.
Know what you are opening.

24 citation formats, real examples, and a small decoder for common statutory, regulatory, IRS, and Tax Court references.

A citation tells you where a statement came from. It does not, by itself, tell you whether the statement controls your issue, applies to your year, survived appeal, or remains current. Start with the source family, then read the text and its history.

Examples: IRC § 704(b), Treas. Reg. § 1.704-1(b)(2), Rev. Proc. 2026-35.

No document is uploaded or sent. This browser-local tool recognizes a limited set of formats; it is not a full-text database, case citator, or legal-validity checker.

Citation anatomy

26 U.S.C. § 704(b)

Title
26
Section
704
Subsection
(b)

The statutory format is recognized. The section link was checked for this edition. Nested subdivisions and applicability still require reading the source.

A bare § number needs context: § 704 of the Code is different from a regulation section. Check the version and effective date.
Open the verified Code section ↗
01–24

Find the source family.

24 formats

Statutes

IRC / I.R.C. / U.S.C.

Internal Revenue Code / United States Code

The federal tax Code is codified in Title 26 of the United States Code. I.R.C. § 704 and 26 U.S.C. § 704 point to that same statutory section.

26 U.S.C. § 704(b)
Read the components and limits

26 = title; 704 = section; (b) = subsection. Further (2), (A), (i) identify nested subdivisions.

A bare § number needs context: § 704 of the Code is different from a regulation section. Check the version and effective date.

Official source / citation guide ↗
Regulations

C.F.R. / Treas. Reg.

Code of Federal Regulations / Treasury regulation

C.F.R. identifies codified federal regulations. Treas. Reg. identifies a Treasury regulation; federal tax regulations generally appear in Title 26.

Treas. Reg. § 1.704-1(b)(2)
Read the components and limits

1.704-1 = complete regulation section number in Part 1; (b)(2) = nested paragraphs. It is not IRC § 1.704.

Distinguish final, temporary, and proposed text. The eCFR is an updated editorial compilation; verify the relevant historical version.

Official source / citation guide ↗
Regulations

T.D.

Treasury Decision

A Treasury Decision publishes final or temporary Treasury regulations and their accompanying material. It identifies the rulemaking document, not a Code section.

T.D. 10000
Read the components and limits

10000 = Treasury Decision number. The accompanying Federal Register citation locates its publication.

Read the actual regulatory text and applicability provisions; do not treat a preamble sentence as a substitute for the rule.

Official source / citation guide ↗
Regulations

F.R. / Fed. Reg.

Federal Register

The Federal Register publishes rulemaking documents, notices, and other federal material. A citation locates a document in the daily publication.

89 F.R. 56480 (2024)
Read the components and limits

89 = volume; 56480 = first page; 2024 = publication year. This is the publication citation associated with T.D. 10000.

Publication date, effective date, and applicability date can differ. Locate all three before applying a regulation.

Official source / citation guide ↗
Published guidance

Rev. Rul.

Revenue ruling

Published IRS interpretation applying tax law to stated facts. Its fact pattern and later treatment matter to research.

Rev. Rul. 76-12, 1976-2 C.B. 88
Read the components and limits

76-12 = ruling year/sequence as printed; 1976-2 = second Cumulative Bulletin volume for 1976; 88 = first page.

This historical example teaches citation form. It does not assert that the ruling remains applicable or unchanged.

Official source / citation guide ↗
Published guidance

Rev. Proc.

Revenue procedure

Published IRS procedure or other administrative guidance. The citation year identifies its series, not necessarily the tax year to which every provision applies.

Rev. Proc. 2026-35
Read the components and limits

2026 = procedure series year; 35 = sequence number. This actual document contains 2027 inflation-adjusted items.

Read purpose, scope, effective dates, and any modifications or superseding guidance.

Official source / citation guide ↗
Published guidance

Notice

IRS notice in published guidance

A published Notice can announce substantive guidance, transitional treatment, or a request for comments. Here “Notice” means that document family.

Notice 95-67, 1995-2 C.B. 343
Read the components and limits

95-67 = year/sequence as printed; 1995-2 C.B. 343 = publication location.

Do not confuse a guidance Notice with a taxpayer account letter such as CP14. Historical numbering does not establish current applicability.

Official source / citation guide ↗
Published guidance

Announcement

IRS announcement

A public IRS pronouncement, often about an immediate administrative matter, publication, deadline, or clarification. Read what the particular announcement actually does.

Announcement 96-124, 1996-49 I.R.B. 22
Read the components and limits

96-124 = document year/sequence; 1996-49 = bulletin year/issue; 22 = page.

A document’s label alone does not establish that its subject or relief still applies.

Official source / citation guide ↗
Published guidance

I.R.B.

Internal Revenue Bulletin

The IRS publication containing revenue rulings, revenue procedures, Treasury Decisions, notices, and other material. It is a publication container, not one single type of rule.

2026-46 I.R.B.
Read the components and limits

2026 = publication year; 46 = issue number. A complete document citation may add its first page and a pinpoint page.

An issue number is not a document number. Rev. Proc. 2026-35 is not automatically found in bulletin 2026-35.

Official source / citation guide ↗
Published guidance

C.B.

Cumulative Bulletin

An older consolidated IRS publication cited frequently in historical tax research. The volume and page locate the material.

Rev. Rul. 63-107, 1963-1 C.B. 71, 74
Read the components and limits

1963-1 = first volume for 1963; 71 = first page; 74 = pinpoint page being discussed.

A pinpoint page is not another ruling number. Check the document’s later history and the law for the relevant year.

Official source / citation guide ↗
Advice & litigation positions

PLR

Private letter ruling

A written determination applying law to a particular taxpayer’s stated facts. Public release removes identifying information; it does not turn the ruling into general precedent.

PLR 8210019
Read the components and limits

The IRS citation guide uses this older seven-digit example: 82 identifies the 1982 release series. Modern weekly release identifiers normally have nine digits.

Section 6110(k)(3) generally bars using or citing written determinations as precedent. A ruling’s protection for its own recipient is a separate question.

Official source / citation guide ↗
Advice & litigation positions

TAM

Technical advice memorandum

Chief Counsel advice requested through the IRS in a specific taxpayer proceeding, often an examination or refund matter. It addresses an already completed transaction.

TAM 9643001
Read the components and limits

96 identifies the 1996 release series in this historical IRS citation example. The remaining digits identify the weekly release and sequence.

Do not apply the specific taxpayer’s determination to another case as precedent; see § 6110(k)(3).

Official source / citation guide ↗
Advice & litigation positions

CCA

Chief Counsel Advice

Disclosed Chief Counsel advice to IRS personnel. Its legal analysis can help locate issues and authorities, but the document is not precedential authority for another taxpayer.

CCA 202504014
Read the components and limits

2025 / 04 / 014 identifies the public-release series, weekly group, and sequence. The document was released January 24, 2025, but dated July 17, 2024.

The release number is not the original advice date. This advice expressly states it may not be used or cited as precedent.

Official source / citation guide ↗
Advice & litigation positions

AOD / acq. / nonacq.

Action on Decision / acquiescence status

An AOD announces the IRS’s future litigation position concerning a court decision. “Acq.” and “nonacq.” describe acquiescence or nonacquiescence, not an appellate ruling.

AOD 2026-04
Read the components and limits

2026 = AOD series year; 04 = sequence. This document concerns Mylan and related capitalization litigation.

An AOD is not the judicial opinion. The example expressly says taxpayers must not rely on or cite the AOD as precedent.

Official source / citation guide ↗
IRS operating material

IRM

Internal Revenue Manual

IRS internal operating policies and instructions. Useful for understanding administrative procedures and locating related authorities.

IRM 4.10.7.2.6
Read the components and limits

4.10.7 identifies a manual section; .2.6 locates a nested subsection about revenue rulings and procedures. Revision dates belong to the particular provision.

The IRM does not itself have the force of law or independently create substantive taxpayer rights. Locate the controlling law and distinguish policy from statute.

Official source / citation guide ↗
IRS operating material

ATG

Audit Techniques Guide

Industry-focused IRS examination guidance covering practices, records, and recurring audit issues. It can supply useful questions for understanding an industry.

Construction Industry Audit Techniques Guide (04/2021)
Read the components and limits

Read the title and publication date; ATGs do not share one universal year-sequence citation system.

The IRS warns that later changes can affect a guide’s technical accuracy. An audit guide is not a statute or a guarantee of a deduction.

Official source / citation guide ↗
Court citations

T.C.

Tax Court Reports / division opinion

A reporter citation to a Tax Court division opinion. The volume and first page locate the opinion; additional pages can pinpoint a proposition.

Stewart v. Commissioner, 127 T.C. 109 (2006)
Read the components and limits

127 = volume; T.C. = reporter; 109 = first page; 2006 = decision year.

Read the holding, controlling jurisdiction, and later appellate history. The reporter label alone does not establish that a proposition remains good law.

Official source / citation guide ↗
Court citations

T.C. Memo.

Tax Court memorandum opinion

A Tax Court memorandum opinion identified by year and sequential opinion number. It is a judicial opinion, not an IRS technical advice memorandum.

Estate of Griffin v. Commissioner, T.C. Memo. 2025-47
Read the components and limits

2025 = opinion year; 47 = opinion number. A pinpoint such as “at *5” refers to the opinion’s star page.

Do not equate a memorandum opinion with a § 7463 summary opinion. Check its reasoning, court treatment, appeal history, and the proposition being cited.

Official source / citation guide ↗
Court citations

T.C. Summary Op.

Tax Court summary opinion

An opinion arising under small-tax-case procedures. This is a different category from a memorandum opinion.

Salzer v. Commissioner, T.C. Summary Opinion 2014-59
Read the components and limits

2014 = opinion year; 59 = sequence in the summary-opinion series.

Section 7463(b) makes the decision unreviewable in another court and not precedent for another case. Do not use it as ordinary precedential authority.

Official source / citation guide ↗
Court citations

B.T.A.

Board of Tax Appeals Reports

The Board of Tax Appeals preceded the Tax Court. Its reporter appears in older opinions and secondary sources.

Simons Brick Co., 14 B.T.A. 878
Read the components and limits

14 = reporter volume; B.T.A. = Board reporter; 878 = first page.

Old Code numbering and later changes can alter the relevance of an older decision. Age alone neither validates nor disposes of its reasoning.

Official source / citation guide ↗
Court citations

F.3d / F.4th

Federal Reporter, Third / Fourth Series

Reporter series used for published federal appellate opinions. “3d” or “4th” names the reporter series, not the circuit that decided the case.

Kroner v. Commissioner, 48 F.4th 1272 (11th Cir. 2022)
Read the components and limits

48 = volume; F.4th = reporter series; 1272 = first page; 11th Cir. = court; 2022 = year. The manual also cites 17 F.3d 965 (7th Cir. 1994).

Reporter series do not rank decisions. Identify the relevant circuit, holding, subsequent history, and any jurisdiction-specific rule.

Official source / citation guide ↗
Court citations

F. Supp.

Federal Supplement

A reporter used for federal district-court opinions. It differs from the Federal Reporter used for appellate opinions.

Stahl v. United States, 294 F. Supp. 243 (D.D.C. 1969)
Read the components and limits

294 = volume; 243 = first page; D.D.C. = District of Columbia district court; 1969 = decision year.

A reporter citation does not establish binding effect outside the relevant court system. Check the court and later history.

Official source / citation guide ↗
Court citations

U.S.

United States Reports

The official reporter of Supreme Court decisions. In this citation position, U.S. identifies the reporter, not the United States Code.

Welch v. Helvering, 290 U.S. 111 (1933)
Read the components and limits

290 = volume; U.S. = reporter; 111 = first page; 1933 = decision year. Compare “26 U.S.C. § 704,” a statute.

A case may interpret older statutory language. Read the issue, holding, later legislation, and later decisions before applying it.

Official source / citation guide ↗
Statutes

Pub. L. / Stat.

Public Law / Statutes at Large

A Public Law citation identifies an enacted session law; Stat. locates it in the Statutes at Large. Codified Code sections can later change.

Pub. L. No. 117-58, 135 Stat. 429 (2021)
Read the components and limits

117 = Congress; 58 = public-law number; 135 = Statutes at Large volume; 429 = first page; 2021 = enactment year.

A session law section is not necessarily the same number as the amended Code section. Inspect amendment and effective-date language.

Official source / citation guide ↗

Three distinctions that prevent bad research

  • A published revenue ruling is different from a private letter ruling. Section 6110(k)(3) generally prevents treating PLR, TAM, and CCA written determinations as precedent.
  • A Tax Court memorandum opinion is different from a small-tax-case summary opinion. Section 7463(b) imposes the latter’s no-review and no-precedent limits.
  • IRS operating instructions are different from the law they administer. A source can help explain a process without independently creating a taxpayer right or proving a deduction.

Sources and verification

Examples were checked against official IRS and court materials on November 15, 2026. Historical citations illustrate syntax, not continued substantive validity. The live decoder verifies neither every typed paragraph nor arbitrary case numbers.

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