Tips for Note-Taking During Research for a Law Review Article?

A student of mine had a great question:

This may seem really obvious, but I was wondering if you had any advice on note-taking methodology in connection with paper research. I find it really helpful to take notes/read more "actively", but am not sure its prudent to approach the material the same way I approached reading/briefing for classes. As I haven't yet pinned down the essence of my claim at this stage, I've just been writing down the holdings/reasoning/ambiguities I think could potentially be relevant, as well as some of the more promising citations in each text. Does that sound like a reasonable tactic? Or, in your experience, is there any particular approach that you feel best maximizes the value of your research and reading of cases?

I have some general thoughts, but the trouble is that I'm now many years removed from my first law review article research tasks, and while I've thought enough about other aspects of academic legal writing to overcome this handicap, I haven't thought enough about the specific task of note-taking during research. I'd therefore love to tap the collective wisdom of our readers who might have more immediate experience with this. What note-taking strategies have worked well for you when you're trying to read, digest, and summarize for your future reference a large and new body of law and of scholarship, with an eye towards writing your own law review article?