What are Revenue Procedures?
IRS Publications are officially published by the IRS.
They are directed to all taxpayers.
"A revenue procedure (Rev. Proc.) is issued to assist taxpayers in complying with procedural issues that deal with tax return preparation and compliance" (IRM 22.214.171.124.6).
Revenue Procedures are numbered consecutively each year ( i.e. Rev. Proc. 2014-6 is the 6th revenue procedure issued in 2014). It should be noted that many revenue procedures are issued regularly each year. For example, the first procedure issued each year (2012-1, 2013-1, 2014-1, etc.) provides the current procedures for obtaining letter rulings, determination letters and closing agreements.
"Rulings do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. In applying published rulings, the effects of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered. Caution is urged against reaching the same conclusion in other cases, unless the facts and circumstances are substantially the same" (IRM 126.96.36.199.6.1, Authority of Rulings and Procedure).
Revenue Procedures may be used as "substantial authority" to avoid the substantial understatement penalty.
How Do I Access Revenue Procedures?
- Via the Internal Revenue Bulletins available from IRS.gov
Electronic to Authorized Users:
- Via WestlawNext
- Via Bloomberg Law
- (From the Tax Practice Center, choose Regulatory Agencies and then Revenue Procedures)
- Via RIA Checkpoint
- (From the main page, under Primary Source Materials, click the + next to IRS Rulings and Releases, and then choose Revenue Procedures)
- Via the Bloomberg/BNA Tax and Accounting Center
- Via LexisNexis Academic
- Via CCH Intelliconnect