1Facts
Start from your client’s facts.
Describe the fact pattern the way you would brief a colleague. The facts you give shape what the research looks for.
For tax attorneys
Test a ruling against your fact pattern.
Read what the IRS concluded, on which page and on what record, before a ruling reaches your memo.
Illustrative
The situation
A ruling looks close to your client’s facts. Read what it concluded, and on what record.
Before it goes in a memo, open the page that states the standard beside the page that applies it, with the ruling’s status in view.
How the work goes
From a fact pattern to a memo.
Four moves from a client’s facts to a memo you can defend, each with the source in view.
2Rulings
Find the rulings closest to them.
Rulings that bear on the question come forward with their status; the ones that turn on a different election are set aside.
3Law and conclusion
Read the law and the conclusion together.
Open the page that states the standard beside the page that applies it, each passage marked where the IRS wrote it.
4Memo
Draft with every citation in place.
Accept a research addition into your memo and it brings its citation and its authority label with it.
Read next
Before you rely on it, read the record.
Other roles
One trail. Different work to do.
Bring a fact pattern.
See a question, its cited answer and the ruling page together.
Every sentence cites the page it came from.