For in-house tax teams
Bring the cited record to the decision.
Show the people who sign off the sources behind a position: publisher, page, authority, and what is still open.
Illustrative situation
A position needs sign-off.
A subsidiary missed an election deadline and the return is due. The approver should see how the IRS has treated the situation before agreeing to file on it.
A conclusion alone asks them to trust the summary. A record lets them read the sources and see which are authority and which are only background.
| Source | Location | Authority | Used for |
|---|---|---|---|
| IRS Private Letter Ruling 202627005 | Page 4 · Conclusion | Non-precedential | How the IRS treated late QSub elections on one taxpayer’s facts |
| §§ 301.9100-1 to 301.9100-3 | Cited on page 4 of the ruling | Regulation, read in its official text | The standard for more time to make an election |
| Company facts memo | Internal, dated by the team | Not a source in the library | Where our facts differ from the ruling’s |
How the work goes
From a question to an approved position.
Four moves from the question on your desk to a position the approver can read in full.
[01] Frame
Frame the position as one question.
Ask it the way the decision will be asked, and choose the collections that can answer it.[02] Weigh
Sort the support by its authority.
The Code and the regulations are authority. A written determination is labelled nonprecedential, so it is read as the IRS’s answer to one request.[03] Open questions
Write down what is still open.
Where your facts differ from the source’s, say so in the record, before the approver has to ask.[04] Sign-off
Take the record to sign-off.
The approver sees the position with every source, its location and its authority, and the open question beside it.
Try it
Answer the approver’s questions.
The approver has three questions. See how the record answers each one.
Choose one to see it play.
At sign-off
The status is in the answer.
Where the record stops.
A cited record covers what the library holds. It does not stand in for material the library does not cover:
- Records available only by request, and older records not published electronically.
- Commercial commentary, treatises, editorial headnotes and newsletters.
- A full citator tracking every later document that follows or criticizes a source.
The full list is on Sources, and what “searchable” means explains what a missing result does and does not show.
Review with the record in hand.
See the source view and talk through the controls your team needs.