Vol. III
The Architecture of Civil Procedure
MMXXVI
Forthcoming
The Architecture of Civil Procedure
Pleadings, motions, and the path of a case.
Faculty of the School of Civil Procedure
A School of the Academy
Department of Federal Taxation
Federal income tax, procedure, and primary tax authority.
§ 0·a
The Record
§ 0·b
Foundational Treatise
A series on the Internal Revenue Manual as an operational and procedural authority.
1 chapter published
Open the treatise in the Press →§ I
Introduction
Scope of Study
Taxation
Tax is read in layers: Code, Regulations, published rulings, then case law. The School works in that order and stops where the authority stops.
§ I·b·2
Subject Navigation
Each group below is generated from the Society's own taxonomy — the Parts of the School's treatises, its editorial categories, and its Library divisions.
§ I·d
Research Areas
Press Category
Internal Revenue Manual1 record
Press Category
Revenue Rulings1 record
§ II
Philosophy of the School
On how this School reads.
§ III
What Students Will Study
A School commits to a set of questions and to a method of reading them. The following are the working commitments of this department.
The structure of the Internal Revenue Code and its reading conventions
The weight accorded to Treasury Regulations and published guidance
The procedural avenues for contesting a federal tax determination
The information-reporting and withholding regime
The intersection of substantive tax doctrine with administrative law
§ IV
Curriculum
The syllabus is read in sequence. Foundations are not optional; advanced study presumes them.
Foundations
Reading a Code section: subsections, paragraphs, and cross-references
Gross income, exclusions, and the assignment-of-income doctrine
Deductions, credits, and the standard of substantiation
Intermediate Study
Treasury Regulations: legislative, interpretive, and procedural
Revenue Rulings and the levels of published guidance
Audit, examination, and the thirty-day letter
Advanced Study
Tax Court jurisdiction and the ninety-day letter
Refund procedure in district court and the Court of Federal Claims
Penalties, the reasonable-cause defense, and supervisory approval
Research & Method
Locating Treasury Regulations under a Code section
Reading the Internal Revenue Bulletin for current guidance
Tracing a doctrine from Code to Regulation to Ruling to case
Reference Materials
Title 26, U.S. Code
Title 26, Code of Federal Regulations
Internal Revenue Bulletin
Suggested Reading
Bittker & Lokken, Federal Taxation of Income, Estates and Gifts
Saltzman & Book, IRS Practice and Procedure
§ IV·b
Learning Path
A staged reading order — from institutional introduction through primary authority to advanced research.
Introduction
Tax is read in layers: Code, Regulations, published rulings, then case law. The School works in that order and stops where the authority stops.
Working Articles
Editorial articles for this School.
Primary Authorities
Featured entries from the Legal Corpus.
Related Schools
Departments that read alongside this one.
§ V
Learning Outcomes
Outcomes are stated as capacities, not credentials. They describe what a member should be able to do after sustained reading.
Read a Code section in its statutory context
Distinguish levels of published Treasury guidance and the weight each carries
Choose the appropriate procedural forum for a tax controversy
§ VI
Primary Authorities
Authorities are listed by category. Entries marked in preparation are catalogued and reviewed before they enter the working record.
Statutes
1 entry
Authority
Internal Revenue Code (Title 26, U.S. Code)
Regulations
1 entry
Authority
Treasury Regulations (Title 26, C.F.R.)
Judicial Opinions
2 entries
Authority
Reports of the United States Tax Court
In Preparation
Forthcoming — district and circuit case selections in preparation
Administrative Guidance
3 entries
Authority
Revenue Rulings
Authority
Revenue Procedures
Authority
Notices and Announcements in the Internal Revenue Bulletin
Treatises & Restatements
1 entry
Authority
Bittker & Lokken, Federal Taxation of Income, Estates and Gifts
§ VII
Featured Publications
The following volumes are drawn from, or supply, the work of this School. Each is reviewed by faculty before publication.
Vol. I
Estate Administration in Practice
MMXXV
Forthcoming
Procedure, forms, and the record of the probate court.
Faculty of the School of Estate Administration
Monograph No. 1
An Introduction to Legal Research
MMXXV
In Press
The hierarchy of authority and the discipline of citation.
Faculty of the School of Legal Research
The Society Press
All publications →§ VII·b
From the Press
Editorial articles tagged to the subjects of this School, drawn from the Real Law Society Press.
Press · Article
How to Read a Revenue RulingThe structure that governs every Revenue Ruling: Issue, Facts, Law and Analysis, Holding, Application
Press · Article
Reading the Internal Revenue ManualThe IRM's part–chapter–section structure, and what weight to give it
Press · Article
The Concept of PropertyChapter 3
Press · Article
Classifications of Property and the Doctrine of FixturesChapter 4
Press · Article
Community PropertyChapter 19
§ VII·e
Research Collections
Collection
Internal Revenue Code Collection
Title 26 of the United States Code — statutory federal tax law.
Collection
Internal Revenue Manual Collection
The IRS's internal operating instructions — assessment, collection, examination.
Collection
Federal Tax Collection
The full federal tax record: statutes, regulations, IRS guidance, and the IRM.
§ VII·f
Legal Corpus
Entries drawn from the Real Law Society Legal Corpus that supply the primary reading of this School.
internal-revenue-manual
IRM 1.11.1 — Internal Management Document (IMD) Program and Responsibilities
internal-revenue-manual
IRM 1.11.2 — Internal Revenue Manual (IRM) Process
internal-revenue-manual
IRM 1.11.6 — Using and Researching the Internal Revenue Manual (IRM)
internal-revenue-manual
IRM 4.10.1 — Overview of Examiner Responsibilities
internal-revenue-manual
IRM 25.6.1 — Statute of Limitations Processes and Procedures
internal-revenue-manual
IRM 20.1.1 — Introduction and Penalty Relief
internal-revenue-manual
IRM 20.2.1 — Interest Introduction, Standards and Guidelines
internal-revenue-manual
IRM 5.1.9 — Collection Appeal Rights
internal-revenue-manual
IRM 5.1.10 — Taxpayer Contacts
internal-revenue-manual
IRM 5.1.19 — Collection Statute Expiration
internal-revenue-manual
IRM 5.11.1 — Background, Pre-Levy Actions, Restrictions on Levy & Post-Levy Actions
internal-revenue-manual
IRM 5.11.2 — Serving Levies, Releasing Levies and Returning Property
§ VIII
Research in the Library
The divisions below carry the primary materials this School draws on. The catalogue opens in stages as the index is reviewed.
Library Division
Codified federal and state statutory law, organized by title and chapter.
Library Division
The Code of Federal Regulations and state administrative codes.
Library Division
Agency interpretive material — revenue rulings, advisory opinions, and policy statements.
Catalogue · XI Divisions
Enter the Research Library →§ IX
Related Schools
Doctrine does not respect departmental boundaries. The following Schools take up adjacent questions.
§ X
Timeline
The institutional record — publications, articles, primary authorities, and journal notices — in date order.
Press · Article
Community PropertyPress · Article
Classifications of Property and the Doctrine of FixturesPress · Article
The Concept of PropertyPress · Article
How to Read a Revenue RulingPress · Article
Reading the Internal Revenue ManualInternal Revenue Manual § 1.11.2
IRM 1.11.2 — Internal Revenue Manual (IRM) ProcessTreatise
The Architecture of Civil Procedure
Internal Revenue Manual § 1.11.6
IRM 1.11.6 — Using and Researching the Internal Revenue Manual (IRM)§ XI
Continue Research
A short standing recommendation drawn across the institutional record.
Publication
The Architecture of Civil Procedure
Research Collection
Internal Revenue Code Collection§ XI
Browse This Subject
Each gateway opens the family surface in which this School's records are catalogued.
Treatises, manuals, and monographs of this School.
3 records
Primary law catalogued in the Legal Corpus.
67 records
Editorial articles and treatise chapters.
5 records
Working collections assembled for research.
3 records
Admission
All Founding Members are admitted into every School. Tuition and dues are not yet open.