Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


4,000 Tax Cases and Rulings

2023-03-27

Whenever I read a tax case or an IRS ruling, I print it out and use a highlighter to indicate the portions I find important. I also save an electronic version of the document. I have printed and electronic copies of the cases and rulings that I have read for over 30 years.

I keep track of these documents in three general categories:

  1. Cases;
  2. Revenue Rulings, Revenue Procedures, and Notices; and
  3. PLRs, TAMs, CCAs, PMTAs, GCMs, AMs, FSAs, INFOs, ILMs, FAAs, etc.

Indexing Cases & Rulings

Years ago I realized that I would vaguely remember a rule or principle, but I was unable to locate the origin of the rule or principle. I therefore created an Excel file to index the documents I had read.

For each item in the index, I include the name, citation, relevant code sections, a brief description of the key concepts in the document, and related cases or rulings. As I draft each description, I think of “what would I search for” if I were looking for this case or principle. A sample of a few of my index items looks like:

sample of cases and rulings index

On average, I tend to read a new case or ruling every two or three days. So far in 2023, I have read 37 cases and rulings. Last year I read 155 cases and rulings. In total, I have read and indexed over 4,000 cases and rulings.

Flashcards

I export the index of cases and rulings to a text file so that I can import it into a flashcards app on my phone and iPad. This app has some powerful features. For example, if I want to see all of the cases and rulings that I have read that deal with treaties, I can just type in “894”. This is the code section I use to identify treaties, and the app will show me all of the items that discuss treaties.

If I have time to kill, such as standing in line for coffee, I will often open the flashcards app and review the descriptions of recent cases or rulings I have read.

Tags: Authority - Notices, Authority - PLRs / CCAs, Authority - Revenue Procedures, Authority - Revenue Rulings, Other - Other