Three Types of Tax Law Sources

Discussion Questions
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Part a: (i) Judicial sources: decisions from courts are official applications and interpretations of the Internal Revenue Code (IRC) by the government’s judicial branch. Judicial sources include tax court, U.S. District Court, U.S. Claims Court, U.S. Circuits Courts of Appeal, and U.S. Supreme Court. (ii) Administrative sources: the Treasury Department in the United States is responsible for administering the tax laws. In order to attain this charge, it makes different pronouncements to elucidate the IRC. Administration sources include rulings from the Internal Revenue Service (IRS), treasury regulations, revenue procedures from the IRS, private letter rulings, and general counsel memorandums. (iii) The statutory source includes the IRC, which is the statutory foundation of every federal tax authority (Internal Revenue Service, 2014). Other than being issued by dissimilar groups, the purposes and format of these sources are dissimilar. Administrative and judicial authorities ordinarily interpret the ratified laws, while the statutory authorities are the tax laws ratified by the U.S. Congress.
Part b: Regulations are basically statements of general applicability which are used in communicating policy or law, interpreting law, explaining how to apply law, or in describing the procedure/practice and organization requirements of the specific agency of the government. Regulations are issued in order to give guidance to taxpayers along with their advisors about the government’s interpretation of the Internal Revenue Code (Internal Revenue Service, 2014). Revenue rulings are different from regulations since they are official statements by the IRS with regard to its interpretation of the IRC’s provisions, regulations, plu...