Procedurally, a tax case may arise in one of two ways. A taxpayer may elect not to pay the contested taxes and may petition the United States Tax Court to have the assessment overturned. If the court rules in favor of the taxpayer, the IRS can elect to accept the decision (acquiescence) or pursue the matter further (non-acquiescence.) Alternatively, the taxpayer may elect to pay the taxes and then sue the government for a refund. Such a suit would commence in U.S. District Court or the U.S. Court of Federal Claims. Decisions of the Tax Court and District Courts are appealed to the U.S. Court of Appeals covering the taxpayers geographic location. Decisions of the Court of Federal Claims are appealed to the Court of Appeals for the Federal Circuit.
Because tax cases are heard in various courts, tax decisions are reported in a variety of reporters, including the Federal Reporter (F., F.2d, F.3d), the Federal Supplement (F. Supp., F. Supp. 2d, F. Supp. 3d), and the specialty case reporters listed below. Opinions are available in official publications as well as unofficial reporters that tie in with looseleaf services like the Standard Federal Tax Reporter (CCH) and United States Tax Reporter (RIA). Be aware that the similarity in reporter abbreviations, changes in publisher names, and changes in reporter titles can cause some confusion.
Research Tip: A good starting point for locating relevant decisions for a code section is to consult the summaries of cases and IRS pronouncements that follow the code section in looseleaf services or to review the case annotations that follow the code section in an annotated version of the code.
Citators provide parallel citations, the procedural history of the dispute, and citations to later cases and IRS interpretations (such as revenue rulings) that cite the document you are working with. Several of the citators that can be used to evaluate the status and authority of a tax decision are listed below. Note that the RIA citator is arranged by case name rather than citation, and contains citations to more types of IRS materials.