Cirsium tracyi occurs from eastern Utah and western Colorado south in the Colorado Plateau and southern Rocky Mountains to northwestern New Mexico. Large-headed plants of Cirsium tracyi and small-headed individuals of C. undulatum are sometimes difficult to distinguish. P. L. Barlow-Irick (unpubl.) found that although there is much overlap in floral measurements of C. tracyi and C. undulatum, the means for some of these characters are statistically significant. Corolla lobes of C. tracyi, for instance, average about 7 mm and those of C. undulatum about 10 mm. The species differ in chromosome number as well.