TCP — Quick Sheet
Tax Research & Documentation
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One-minute revision
- Primary: IRC (highest) → Treasury Regs (final > temp > proposed) → Rev. Rulings/Procedures → case law
- PLRs bind only the requesting taxpayer
- Secondary sources (treatises, journals) are never citable authority
- Confidence ladder: reasonable basis → substantial authority → more likely than not → should → will
- Form 8275 disclosure lowers the preparer standard from substantial authority to reasonable basis
- Memo must address contrary authority; check for superseded/obsoleted guidance