United States Tax Law

Mon, 06 Jul 2026 00:00:00 +0000

Sources of US Tax Law

The primary federal tax statute is the Internal Revenue Code of 1986 (IRC), codified in Title 26 of the United States Code. The IRC is the product of successive legislative enactments, most significantly the Tax Reform Act of 1986 and the Tax Cuts and Jobs Act of 2017 (TCJA). The Treasury Department promulgates interpretive regulations under the authority of § 7805 of the IRC, which carry the force of law. Treasury Regulations are classified as legislative, interpretative, or procedural, with varying levels of judicial deference under the Chevron doctrine. The Internal Revenue Service (IRS) issues Revenue Rulings and Revenue Procedures as administrative guidance, binding on the IRS but not on taxpayers. The US Tax Court, established under Article I of the Constitution, provides a pre-payment forum for taxpayers to challenge deficiency determinations. Federal district courts, the Court of Federal Claims, and the circuit Courts of Appeals adjudicate tax matters, with the Supreme Court exercising certiorari review. In Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955), the Supreme Court defined gross income broadly as “accessions to wealth, clearly realized, over which the taxpayer has complete dominion.”

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United States Tax Law

Sources of US Tax Law