The Tax Intelligence Platform · Built for Tax Attorneys

Tax intelligence forresearch.

One platform for the full engagement — research, planning, modeling, review, and controversy. Built for the tax attorney who needs authority that holds up in an opinion letter and in Tax Court.

Per-client data isolation · Every answer cites primary authority
DM
D. Marchetti, J.D., LL.M.
Tax controversy & litigation
LIVE
Does the §7701(o) economic substance doctrine apply to a straightforward §351 incorporation?
TaxFigure
No. §7701(o) applies only where the economic substance doctrine is "relevant." Notice 2014-58 confirms the IRS will not raise it against transactions where Congress clearly intended the tax results — a §351 incorporation meeting the statutory requirements is respected on its terms.
IRC §7701(o)Notice 2014-58IRC §351
Click any citation to read the primary source
50+
State jurisdictions
1,000+
Municipal codes
~2 min
Average research time
100%
Citeable answers
The Tax Attorney Advantage

Authority that holds up —
in the letter and in court.

An opinion is only as strong as the authority behind it. TaxFigure delivers tax-specific depth, anchored to primary sources, ready to cite at the confidence level the engagement requires.

Beyond a general database

Tax depth a general tool can't reach

Code, regulations, rulings, and tax-specific caselaw — the depth a general legal database treats as a footnote, TaxFigure treats as the subject.

Opinion-letter ready

Every position, source-anchored

Each answer is tied to primary authority you can quote directly — the substantiation an opinion at "more likely than not" or "will" demands.

Controversy, prepared

Precedent for the exam and the docket

Tax Court and appellate precedent, procedural authority, and penalty defense — assembled for examination, Appeals, and litigation.

One Engine · Five Workflows

From the first question to the final resolution

Move across the entire engagement without leaving the platform — or losing context. Every answer, model, and review is anchored to the same citeable authority.

Research

Citeable answers

IRC, Regs, rulings, and tax-specific caselaw in seconds — depth a general database treats as a footnote.

Planning

Structuring strategy

Structure, election, and transaction-step analysis — the work that becomes the opinion letter.

Modeling

What-if, quantified

Basis, waterfalls, §199A, and alternative-structure outcomes — quantified for the letter and the deal.

Reviews

Position review

Reporting positions, disclosure adequacy, and consistency — checked against the standard the file will be measured by.

Controversy

Examination to litigation

Penalty defense, Appeals strategy, Tax Court precedent — assembled and cited for the docket.

Where Tax Attorneys Practice

From the opinion letter
to the courtroom

Whether the deliverable is a reasoned opinion or a Tax Court brief, the work stands on authority. TaxFigure assembles it — primary, current, and ready to quote.

See a controversy walkthrough

Opinion letters & confidence levels

Authority assembled to support a position at the standard the engagement requires — from "substantial authority" to "will."

Controversy & litigation

Tax Court and Circuit precedent, procedural authority, and the burden-of-proof rules for every issue.

Transactional & structuring

Reorganizations, partnership and entity structuring, and the doctrines — step transaction, economic substance — that test them.

Penalty defense & reasonable cause

Accuracy-related penalty defense, disclosure adequacy, and reasonable-cause authority for the client and the practice.

Why It Feels Different

Research you can cite verbatim

Other tools give you a paragraph. TaxFigure gives you a paragraph with its sources attached — and the trail to prove it.

Citeable authority

Every answer carries its sources

Quote the Tax Court memo straight into the brief. Cite the Revenue Procedure verbatim in the opinion. Verbatim authority, sourced, ready for the file.

SUPREME COURTFrank Lyon Co. v. United States
"...a genuine multiple-party transaction with economic substance is to be respected for tax purposes..."
Click to verify source

Natural language

Frame the issue the way you'd frame it to co-counsel — no boolean syntax, no keyword strategy, no associate trained on a query language.

counsel › does the step transaction doctrine apply here?

Multi-jurisdiction

Compare federal, state, and circuit treatment in one query — circuit splits surfaced, not assumed.

9th Cir.Taxpayer
2nd Cir.Government
Tax CourtSplit

A defensible trail

Every answer timestamped and source-anchored — a contemporaneous record of the analysis, ready for the file.

Workflow memory

Research to structuring to controversy — context carries across the matter, not across separate tabs.

Coverage

The whole code. The whole docket.

From the Internal Revenue Code to the latest Tax Court memorandum — the authority a tax practice is built on.

Federal tax

The Internal Revenue Code, Treasury Regulations, revenue rulings, procedures, notices, and legislative history — the substantive depth Westlaw treats as one folder.

IRCTreas. RegsRulings

Caselaw & controversy

Tax Court, district court, Court of Federal Claims, Circuit, and Supreme Court decisions — with circuit splits surfaced, not buried.

Tax CourtAppellateProcedure

State & local tax

All 50 states and 1,000+ municipal jurisdictions — income, franchise, sales, and the constitutional limits the federal practice needs.

SALTNexusMunicipal

Specialty & doctrine coverage

The doctrines tax controversy and transactional work turn on — economic substance, step transaction, reorganizations — assembled with the precedent.

Economic substanceStep transactionReorganizationsPartnership taxEstate & giftInternationalPrivilege & §7525
The Infrastructure Layer

Two engines working underneath

Purpose-built components sit beneath the intelligence engine — so client documents and privileged data are handled the way a practice expects.

TaxScan
Document Intelligence

Vision models parse agreements, returns, K-1s, and transaction documents into clean, structured data — the review work, accelerated.

Parse
Split
Extract
Validate
200+
Form types
99.7%
Accuracy
<3s
Per page
PrivacyVault
Data Privacy Vault

Detects, tokenizes, and governs client PII before it ever reaches a model — strict per-client isolation that respects privilege and confidentiality.

Isolate
Protect
Govern
Comply
SOC 2 Type IIHIPAAGDPRCCPAIRS Pub 1075GLBA
For Your Practice

However you practice tax law, TaxFigure fits

From a solo tax controversy practice to a transactional group — the platform scales to the way tax attorneys actually work.

Controversy & litigation

Build the record — precedent, procedure, and penalty defense — from notice through Tax Court.

Transactional tax counsel

Structure deals and write opinions with the doctrine and authority assembled and current.

Solo & boutique tax law

Carry the research depth of a national tax group without the national-firm overhead.

Estate & wealth tax attorneys

Estate, gift, and fiduciary authority — with the planning and modeling in the same place.

Where the work matters

Built for the opinion letter
and the docket

Your open matter
Tax is the matter
An opinion at a "more likely than not" standard. A Tax Court brief turning on §7701(o). A reorganization measured against step transaction. The depth is the deliverable.
With TaxFigure
Verbatim & cited
The Code section, the regulation, the rev. ruling, the Tax Court memo — quoted verbatim, assembled around the issue, ready to drop into the letter or the brief.

Tax law gets the depth it requires — not the depth a general database gives it as a sub-topic.

Common Questions

Tax attorney questions, answered

What tax counsel asks before bringing TaxFigure into chambers.

Is every answer anchored to primary authority?

Yes — answers carry inline citations with a sources panel linking to the IRC, Treasury Regulations, rulings, and caselaw relied upon, so every proposition can be independently verified against the primary source.

Does coverage include caselaw?

Yes — Tax Court decisions and appellate rulings alongside statutes, regulations, and administrative guidance, across federal, all 50 states, and 1,000+ municipal codes.

Can it produce structured work product?

Slash commands generate structured outputs — research memos and citation lookups — from the conversation, so the path from question to draftable work product is short.

How does it handle matter context?

Anchor a conversation to a specific client entity and answers are scoped to that client's structure, tax years, and uploaded documents. Conversations persist, can be resumed, and can be pinned for active matters.

How is client information protected?

Client PII is detected and tokenized before reaching any model, and each matter lives in an isolated entity workspace with per-matter access control.

Will it defend a position or just summarize?

Answers lead with a conclusion and then walk the authority — the statute, the regulation, the ruling — so you can pressure-test the chain yourself rather than trust a paragraph.

Answers current as of 2026-06-18.

See TaxFigure on your hardest open question

Bring a real opinion question, a real controversy issue, a real structuring problem. We'll deliver the citeable authority — in minutes, not days.

Privilege-conscious by design Per-client data isolation Built by practitioners