1. Citators and Other Finding Devices
Chapter 8
Citators and Other
Finding Devices
William A. Raabe, Gerald E. Whittenburg, &
Debra L. Sanders
Copyright ©2006 Thomson South-Western, Mason, Ohio

2. Basic Research Goals Define the research problem
Find the law that addresses the problem
Apply the law
Reach a conclusion
Communicate the findings to the client

3. What is a Citator?
A citator is a tool through which a tax researcher can learn the history of a case or ruling and evaluate the strength of its holdings.
After locating a relevant case or ruling, the researcher can find out what later cases and rulings have said about it to determine its strength as a current source.

4. Purpose List and organize cases that refer to an earlier case
Learn history of a case along with:
Parallel citations
Lower level cases
Evaluate strength of its holdings
Determine how later cases treat the original holding of a case

5. Evaluation of Cited Case (1 of 2)
Cited Case (original case)
This case is the one being referenced in the citing case.
Facts, issues, or holding are referred to in the citing case

6. Evaluation of Cited Case (2 of 2)
Citing Case
Case referring to an original case
Will contain a cite reference
General cite (CCH)
First page of the citing case
Local or pinpoint cite (RIA & Shepard’s)
The exact page where the cited case is mentioned in the citing case

7. Headnotes
Headnotes
Paragraphs in which editors summarize court’s holding on each issue
Usually one headnote per issue
Do not rely only on the headnotes for supporting your research: read the entire case

8. Commercial Citators Citators which cover only tax cases
CCH
RIA
Shepard’s
Includes tax cases in its law citator:
Westlaw

9. RIA Citator Internet citator is called the “Checkpoint RIA Citator”
Earlier versions were published by Prentice-Hall (PH) and Maxwell Macmillan
The Checkpoint RIA Citator does not include the older PH Citators
For cases earlier than 1954, the paper editions must be used

10. RIA Citator The citator is available on the opening screen
Supports citator retrieval by case name, case citation, or keyword searches
Templates are available for entering citations
All cases listed by taxpayer’s name

11. RIA Citator
RIA’s AFTR2d citation is given along with parallel citations
Judicial history is provided
All of the tax citing cases are listed
Headnote reference numbers are shown
A template is provided so the researcher can determine if IRS administrative rulings are still current

12. RIA Citator
The Citing Cases are listed in chronological order by court:
U.S. Supreme Court
U.S. Courts of Appeals
U.S. Court of Federal Claims
U.S. District Court
U.S. Tax Court
State courts
Treasury Rulings & Decisions

13. RIA Citators Treasury Decisions & Rulings

14. RIA Citator & Case: Upjohn Case

15. RIA Citator for Rev. Proc. 2004-15

16. CCH Citator Accessible through CCH’s Tax Research Network
Lists only citing cases that CCH’s editors deem useful
Covers Federal tax cases since 1913
Separate citators for estate & gift cases and excise tax cases

17. CCH Citator
Drawback: it does not provide evaluations of the citing case
Templates are available for entering case citations
Bold black bullets designate court levels
Highest level court that addressed the case is listed first

18. CCH Citator Limited information about judicial history
Can enter either a case name or the complete citation
Convenient tool: while viewing a case, click the “Check Citator” button to display the citator entries

19. CCH Citator Main Table for Upjohn Case

20. CCH Check Citator with Upjohn Case Citations