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For in-house tax teams

Bring the cited record to the decision.

Show the people who sign off the sources behind a position: publisher, page, authority, and what is still open.

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Illustrative situation

A position needs sign-off.

A subsidiary missed an election deadline and the return is due. The approver should see how the IRS has treated the situation before agreeing to file on it.

A conclusion alone asks them to trust the summary. A record lets them read the sources and see which are authority and which are only background.

Question: did the IRS give more time for missed QSub elections?
SourceLocationAuthorityUsed for
IRS Private Letter Ruling 202627005Page 4 · ConclusionNon-precedentialHow the IRS treated late QSub elections on one taxpayer’s facts
§§ 301.9100-1 to 301.9100-3Cited on page 4 of the rulingRegulation, read in its official textThe standard for more time to make an election
Company facts memoInternal, dated by the teamNot a source in the libraryWhere our facts differ from the ruling’s
Illustrative example. A fictional record for one decision. The ruling and its page are real; the internal memo row is invented.

What goes to sign-off.

  1. 01

    A source list with locators

    Each source appears with its publisher and the page or section the position relies on.

  2. 02

    Authority beside every source

    A nonprecedential ruling is labelled as one, so it is read as the IRS’s answer to one taxpayer.

  3. 03

    The open question, written down

    Where your facts differ from the source’s, the record says so.

At sign-off

The status is in the answer.

VirtusSample workspace · illustrative data
A research answer with numbered citations and, below it, the note that the written determinations it cites are nonprecedential.
A cited answer in the sample workspace. The line under it says that the written determinations it cites are nonprecedential.

Where the record stops.

A cited record covers what the library holds. It does not stand in for material the library does not cover:

  • Records available only by request, and older records not published electronically.
  • Commercial commentary, treatises, editorial headnotes and newsletters.
  • A full citator tracking every later document that follows or criticizes a source.

The full list is on Sources, and what “searchable” means explains what a missing result does and does not show.

Review with the record in hand.

See the source view and talk through the controls your team needs.

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