THE TAX LAWYER Citation and Style Manual: 2010–2011 AUTHORITY The Tax Lawyer adheres to the citation and style rules set forth in this manual (Grey Guide) in the following order of preference: (1) Grey Guide, (2) The Bluebook: A Uniform System of Citation (Bluebook) (Columbia Law Review Ass’n et al. eds., 19th ed. 2010) (ignoring cross-references therein to other sources), and (3) Texas Law Review Manual on Usage & Style (TMOUS) (Texas Law Review Ass’n, 11th ed. 2008). STYLE These style rules apply to regular text and textual material in footnotes, but not to text within a direct quotation. Note that the following set of rules is not comprehensive—please refer to the style rules listed Bluebook and TMOUS, in addition to those listed here. I. Party and Organization Names: 1. Code. In a textual sentence (in the text of the main body or in a footnote), the Internal Revenue Code should be referred to as “the Code.” In a textual reference to a section of the Code, "section" is not capitalized and is not preceded by the word “Code.” Example: The qualification requirements of section 127 are more detailed, explicit, and perhaps stricter than those of section 117(d). Income exempt from taxation under a treaty should also be exempt under the Code. Sections 1 and 11 provide tax rate schedules. In section 514(c) and (d), the participating loan restrictions are relaxed for sales of real property. Sections 53 to 59 govern the application of the Alternative Minimum Tax. Note: When the Internal Revenue Code is referenced in conjunction with the bankruptcy code or another code, an exception may be necessary. 2. Internal Revenue Service. Always refer to the Internal Revenue Service as “the Service,” not “the IRS,” unless the context clearly indicates otherwise (e.g., “IRS” is used in a case name, title of a document, the name of a congressional subcommittee, or in the case of the IRS Chief Counsel Office). 3. Parties. Do not abbreviate “Commissioner” or “United States” when they are parties to a case. Commissioner is generally used only in case names. Likewise, when a state tax commissioner is a party to a case, “Commissioner” should not be abbreviated. Refer to the taxpayer in tax litigation as “the taxpayer,” not as “the plaintiff” or “the petitioner.” II. Punctuation: 1. Hyphens. Err on the side of not using the hyphen and always look up the rule to check yourself. See TMOUS Rule 1.28 to 1.32. "Non" words are not hyphenated. Note: “Carryover, Carryback, Rollover.” Never hyphenate these words. Separate them when used as verbs; combine them when used as nouns. 2. Quotations. Quotation marks must be used when taking words directly from a source. Statutes and regulations can be quoted directly without quotation marks. Note: Disregard Chapter 8 of the TMOUS. 3. Solidus. A solidus ("/") should almost never be used. Instead use an en-dash ("-") or "or." Never use “and/or,” simply use "or . . . or both." INCORRECT: “The Third Circuit rejected a substantive/nonsubstantive distinction in U.S. income tax law.” CORRECT: “The Third Circuit rejected a substantive-nonsubstantive distinction in U.S. income tax law.” 4. Oxford Comma. Include the Oxford comma, the last comma in a list. Example: I love bluebooking with Brea, Mhairi, and Sarah. 5. Dashes. There is a difference between en dashes, em dashes, commas, semi- colons and colons. Refer to TMOUS 1.27(b) to check that you are using these dashes correctly. Em-dash. The em-dash is wider than the en-dash, and sets off words, phrases, clauses, or short sentences that clarify or elaborate the preceding text. o The em-dash typically functions as a substitute for a colon, semicolon, or parentheses. It can also substitute for that is, namely, i.e., and e.g. o There are no spaces before or after the em-dash. o To ensure the correct dash is used, under Microsoft Word you can insert an en-dash through the Insert menu, Symbol option, under the Special Characters tab, or you can simply press the dash button twice, type the following word, then press the space bar and Word will automatically format it into an em-dash. Examples: We condemn—we must condemn—the cruelties of slavery. A brief must have at least three parts—the facts, the issues, and the argument—to qualify for the moot court competition. En-dash. The en-dash is wider than a hyphen but narrower than an em- dash. o The en-dash is used to indicate a numeric range, and for certain compound modifiers. Refer to TMOUS 1.27(b) for further instruction. o When the en-dash is used as a substitute for from . . . to or between . . . and, do not proceed the en-dash with a redundant from or between. o To ensure the correct dash is used, under Microsoft Word you can insert an en-dash through the Insert menu, Symbol option, under the Special Characters tab. Examples: The professor assigned pages 148–75. 6. Ellipses. When using quoted language as a full sentence, retain punctuation and add ellipses at the end of the sentence. When the quoted language is used as a phrase or a clause, do not indicate omissions of matters before or after a quotation according. Review Bluebook rule 5.3 for more detailed instruction. III. Citations: 1. Case names. Case names are not italicized when cited in full in citation sentences. Case names are also note italicized in italicized headings. Example: A. The Continued Relevance of Marbury v. Madison 2. Nonperiodic materials. If a cited source comes out only once, treat it like a book. Refer to Bluebook rule 15 for more detailed instruction. 3. Government documents. Be very careful to check for small caps in government documents. Be sure that you do not use small caps for numbers. Example: STAFF OF THE JOINT COMMITTEE ON TAXATION, GENERAL EXPLANATION OF THE TAX REFORM ACT OF 1986 (1987). 4. Internet and Electronic Media. New rules that address citations to information found on the Internet; widely used commercial databases such as Westlaw and LEXIS; CD-ROMs; microforms; films, broadcasts, and noncommercial video- tapes; and audio recordings, and located in Rule 18 of the Bluebook. 5. Articles and Notes. In an article, the article should refer to itself as “Article,” not “paper,” with Article being capitalized. In a note, the note should refer to itself as “Note,” not “paper,” with Note being capitalized. If an author refers to a Part of his Article, Note, or Comment, “Part” is capitalized. 6. Available At. “Available at" is italicized in footnotes. IV. Numbers: Spell out whole numbers ten and below (rather than 99 and below), but generally follow Chapter 2 of the TMOUS. 1. Punctuation. Use a comma in numbers of four or more digits; however, commas are never used in the numbers of private letter rulings, technical advice memoranda, chief counsel advice, or litigation guideline memoranda. 2. Percent. When the number is spelled out, then spell out “percent.” When the number is expressed in digits, then use the percentage symbol following the number. There is no space between the digits and the percent symbol. Examples: The sales contract made up four percent of the total revenues. The amount of taxes owed rose 20% over the period. 3. Dollars. Use the dollar symbol and digits, unless the dollar symbol would begin the sentence. For dollar amounts of one million or greater, use the following form: Examples: $1 million $3.45 million 4. Page numbers and Years. Page number ranges are marked like 980–99, not 980-999. Years, however, are marked as 1989–1990, not 1989–90. 5. Numbered Series. In a series, use Arabic numerals, not Roman numerals. [(1), (2), and (3), not (i), (ii), and (iii)]. V. Miscellaneous: 1. I.e., e.g. The use of these terms should be restricted to footnotes and parenthetical matter. Both “i.e.,” and “e.g.,” are always italicized and followed by a comma, which is not italicized. These signals are not interchangeable; “i.e.,” means “that is,” and “e.g.,” means “for example.” 2. Empty Spaces. There should be one empty space: Between period and the first word of the next sentence (not two), Between parentheticals, After a colon, After a section symbol (§) or paragraph symbol (¶). Examples: This is once sentence. This is another sentence. Marbury v. Madison, 123 U.S. 123 (1802) (holding that . . . ). Brea purchased three items: books, pencils, and pens. Appellant John Smith was convicted of burglary in violation of MINN STAT. § 336.5. 3. Spelling. Note the following spellings: deductible collectible excludable includable reportable 4. Equations. Equations are italicized. 5. Citation in text. When citing a case in a textual sentence, only include one citation at the end of the sentence. You do not need to include a footnote after the case name. Example: In Taylor v. Commissioner, the court applied a reasonableness test, “because it seemed like the easiest way for [the court] to avoid having to come up with an actual standard.”[FN] 6. Footnote placement. Footnote placement should generally be at the end of the sentence even where there is no quote, unless there are pinpoint cites for different propositions. Example: In Taylor v. Commissioner, the court applied a reasonableness test to the first transaction,[FN1] but a totality of the circumstances test to the second transaction.[FN2] Note: In this case, two footnotes are OK, but only because different propositions are supported by different pinpoint cites. 7. Table of contents. The wording of the article’s table of contents should match the wording of the internal article headings, although the formatting may differ. In general, a table of contents is not used. Particularly lengthy articles may call for a table of contents. 8. Defined terms. All defined terms and abbreviations used in the article that need to be defined should actually be defined. The same variation of the term used consistently. Defined terms should be treated as follows, as per TMOUS Rule 1.5(b): Example: North American Free Trade Association (NAFTA) NOT: North American Free Trade Association (“NAFTA”) FORMATTING The following rules apply to The Tax Lawyer Articles and Notes: 1. Word processing. Microsoft Word is the official word processing program. 2. Font. Base font should be Courier New 12 point font. Footnote font should be Courier New 10 point font. 3. Single Spacing. All Articles and Notes should be double-spaced when submitted, and while being edited. Articles and Notes will be single-spaced when they are sent to the typesetter. 4. Paragraphs. There are no blank lines between paragraphs. There is a single tab (0.5”) at the beginning of each paragraph. The first line of the first paragraph of each new section, however, is not indented. 5. Footnotes. There is no space between the superscript footnote numeral and the first letter of the citation or sentence in the footnote. Microsoft Word automatically inserts this space, so you will have to delete it manually in each footnote. The first line of the footnote should be indented by a single tab from the left margin; subsequent lines of footnote text should be flush with the left margin. In Microsoft Word, use Insert, Reference, Cross-reference to cite footnotes within the work. Do not manually type internal cross-references. 6. Block Quotations. These are indented once on each side. Two carriage returns precede and follow block quotations. Block quote text should be in 10 point font. Block quotes should be justified on both sides. 7. Titles. Articles. Titles of articles are written in bold type and are left-aligned. Two carriage returns (represented in the examples below as [ ) follow a title. The author’s name in capital letters follows the two carriage returns after the article title. Example: A Different Point of Venue: The Plainer Meaning of Section 7482(b)(1) [ [ AUTHOR’S NAME* Titles of notes follow the same format and begin with NOTE in capital letters on its own line. The author’s name appears at the end of the note in italics and aligned to the right. NOTE Retroactivity and the Remains of Chevron Oil After Harper v. Virginia Department of Taxation [ [ END OF NOTE [ Author’s Name 8. Headings. There are four levels of headings: Roman Numeral Headings. Bold; left-aligned; two spaces (not tabs) between the roman numeral and the first word of the heading. I. Introduction [ It is commonly believed that an appeal from the United States Tax Court should be in the federal circuit court where the taxpayer resides. Capital Letter Headings. Italicized; not indented; two spaces between the letter and the first word of the heading. II. Expositions of the Tax Court and Section 7482 [ A. A Brief History of the Tax Court [ In 1924, Congress created the United States Tax Court “to provide a judicial forum in which affected persons could dispute tax deficiencies determined by the Commissioner of Internal Revenue prior to payment of the disputed amounts.” Arabic Numeral Headings. Indented five spaces from the left margin; two spaces between the numeral and the first word of the heading; the number is Roman, and the text is italicized. 2. Hypothetical Two [ Envision a petitioner, involved in a CDP case, who resides in the Eight Circuit. Lowercase Letter Headings. Italicized and indented five spaces from the left margin; two spaces between the letter and the first word of the heading; the heading is followed by a period and is incorporated into the paragraph. a. Congressional Treatment. Several members of Congress have proposed legislation dealing with the taxation of . . . Comprehensive Example. NOTE Retroactivity and the Remains of Chevron Oil After Harper v. Virginia Department of Taxation I. Background A. Supreme Court Action 1. Expenses of Administration a. Congressional Treatment. Congress often . . . . II. Analysis 9. Attribution Footnotes. Authors will often include a footnote that lists their credentials and acknowledges help that they received in the preparation of the work. These footnotes should follow the following format: Occupation, Education, Acknowledgment. Examples: * Professor of Law, Saint Louis University School of Law; Washington University, A.B., 1967; University of Chicago, M.A., 1971; J.D., 1975. The author is grateful to . . . * Senior Tax Attorney, Amoco Corporation; University of Missouri, A.B., 1947; Northwestern University School of Law, LL.B., 1951. The author gratefully acknowledges . . . 10. Student’s Name. For student Notes only, the student’s name should appear in italics at the very end of the text of the main body. Example: By overzealously invading spouse-to-spouse transfers of property and refusing to recognize the productive and valuable nature of women’s economic contributions in the home, the Spotts opinion reinforces the disadvantaged status of women in the legal system and perpetuates gender inequality in society at large. Pamela R. Shisler CITATIONS I. Cases: 1. Tax Decisions of Federal Courts of Appeals Cite to the Federal Reporter (F., F.2d, F.3d), if therein; otherwise, cite to United States Tax Cases (U.S.T.C.) and American Federal Tax Reports (A.F.T.R., A.F.T.R.2d). Miller v. United States, 363 F.3d 999, 1009 (9th Cir. 2004). Miller v. United States, 99-1 U.S.T.C. ¶ 50,447, 74 A.F.T.R.2d 1840(6th Cir. 1994). 2. Tax Decisions of Federal District Courts Cite to the Federal Supplement (F. Supp.), if therein; otherwise, cite to United States Tax Cases (U.S.T.C.) and American Federal Tax Reports (A.F.T.R., A.F.T.R.2d). Charlesworth v. Commissioner, 727 F.Supp. 1047, 1412 (D. Mass. 1990). Charlesworth v. Commissioners, 98-2 U.S.T.C. ¶ 55,543, 63 A.F.T.R.2d 1620 (1st Cir. 1990). 3. Tax Decisions of the Court of Federal Claims Cite to the Court of Federal Claims Reporter (Fed. Cl.), if therein; otherwise, cite to United States Tax Cases (U.S.T.C.) and American Federal Tax Reports (A.F.T.R., A.F.T.R.2d). Note: the Court of Federal Claims became effective October 29, 1992. It was previously named the United States Claims Court and was reported in the Claims Court Reporter (Cl. Ct.). Smith v. Commissioner, 30 Fed. Cl. 396 (1994). Smith v. Commissioner, 94-2 U.S.T.C. ¶ 50,386, 74 A.F.T.R.2d 5363(9th Cir. 1994). 4. Tax Decisions of Federal Bankruptcy Courts Cite to the Bankruptcy Reporter (B.R.), if therein; otherwise, cite to United States Tax Cases (U.S.T.C.) and American Federal Tax Reports (A.F.T.R., A.F.T.R.2d), or to the Bankruptcy Law Reporter in that order of preference. In re Bourque, 153 B.R. 87, 89 (Bankr. S.D. Ind. 1993). In re West Texas Marketing Corp., 155 B.R. 399 (Bankr. N.D. Tex. 1993). In re Dextell, 93-1 U.S.T.C. ¶ 50, 3277, 1 A.F.T.R.2d 1626 (1st Cir. 1993). In re Imperial Corp., 1990-91 Bankr. L. Rep. (CCH) ¶ 74,096 (Bankr. S.D. Cal. 1991). 5. Unofficial Reporters In parallel citations to United States Tax Cases (U.S.T.C.) and American Federal Tax Reports (A.F.T.R., A.F.T.R.2d), (A.F.T.R., A.F.T.R.2d). U.S.T.C. is always cited first. Cases are identified by their paragraph number in U.S.T.C. and by their page number in A.F.T.R. For pinpoint and short citations to U.S.T.C., give the paragraph number of the case and the page number of the item being cited. In recent editions of A.F.T.R.2d, the last two digits of the year (e.g., 96) are included before the page number. The THE TAX LAWYER does not include these digits. Full citation: United States v. Goetzl, 74-2 U.S.T.C. ¶ 9787, 34 A.F.T.R.2d 6142 (7th Cir. 1974). Pinpoint citation: United States v. Goetzl, 74-2 U.S.T.C. ¶ 9787, at 10,950, 34 A.F.T.R.2d 6142, 6145 (7th Cir. 1974). Schering-Plough Corp. v. United States, 2007-2 U.S.T.C. ¶ 50,831, at 90,305, 100 A.F.T.R.2d 6864, 6867 (D.N.J. 2007). Short form: Goetzl, 74-2 U.S.T.C. ¶ 9787 at 10,950, 34 A.F.T.R.2d at 6145. 6. Decisions of the Board of Tax Appeals Cite to Board of Tax Appeals Reports (B.T.A.). Thatcher v. Commissioner, 45 B.T.A. 64 (1941). 7. Memorandum Decisions of the Board of Tax Appeals Cite to the Prentice-Hall BOARD OF TAX APPEALS MEMORANDUM DECISIONS (B.T.A. Mem. Dec. (P-H)). Clinton v. Commissioner, 7 B.T.A. Mem. Dec. (P-H) ¶ 54,332 (1939). 8. Regular Decisions of the Tax Court Cite to TAX COURT OF THE UNITED STATES REPORTS (T.C.), if therein; otherwise, cite to TAX COURT REPORTER: REGULAR DECISIONS (T.C.R. (CCH) Dec.) and TAX COURT REPORTED DECISIONS (T.C.R. Dec. (RIA)). Regular Decisions (CCH) use the year as the volume number and therefore no date need be given. Peat Oil & Gas Assoc. v. Commissioner, 100 T.C. 271 (1993). Rose v. Commissioner, 88 T.C. 386 (1987), aff'd, 868 F.2d 851 (6th Cir. 1989). Full citation: Churchill Downs, Inc. v. Commissioner, 2000 T.C.R. (CCH) Dec. 54,059, 115 T.C.R. Dec. (RIA) ¶ 115.20. Short form/pinpoint citation: Churchill Downs, 2000 T.C.R. (CCH) Dec. 54,059 at 4327, 115 T.C.R. Dec. (RIA) ¶ 115.20 at 170. Id. at 4327, 115 T.C.R. Dec. (RIA) ¶ 115.20 at 171. 9. Tax Court Memorandum Decisions There is no official reporter for memorandum decisions. Cite to both CCH TAX COURT MEMORANDUM DECISIONS (T.C.M. (CCH)) and RIA TAX COURT MEMORANDUM DECISIONS (T.C.M. (RIA)). You need to retrieve BOTH books from the library (they are on the fourth floor). CCH does not use the date for the volume number, so a date is required in a CCH cite. RIA does use a date in the volume number, so a date is not required for an RIA cite. Full citation: Milner v. Commissioner, 65 T.C.M. (CCH) 2085, 1993 T.C.M. (RIA) ¶ 93,091. For pinpoint citations to Tax Court Memorandum Decisions (RIA) include the paragraph number of the case and the page number of the item being cited. Pinpoint citation: Milner v. Commissioner, 65 T.C.M. (CCH) 2085, 2087, 1993 T.C.M. (RIA) ¶ 93,091, at 420. Short form: Milner, 65 T.C.M. (CCH) at 2087, 1993 T.C.M. (RIA) ¶ 93,091 at 420. Id. form: Id. at 2087, 1993 T.C.M. (RIA) ¶ 93,091 at 420. Note that citations to cases before 1993 (before the Prentice-Hall (P-H) company was taken over by RIA) may be to the P-H reporter. You must check the publisher of the edition in order to determine which format to use. Barbour v. Commissioner, 3 T.C.M. (CCH) 216, T.C.M. (P-H) ¶ 44,073 (1944). See special cite format for cases decided in the year 2000 or later below: Cases decided in 2000 or later: Hillgren v. Commissioner, 87 T.C.M. (CCH) 1008, 2004 T.C.M. (RIA) ¶ 2004-046. Short form: Hillgren, 87 T.C.M. (CCH) at 1015, 2004 T.C.M. (RIA) ¶ 2004-046 at 22. Id. form: Id. at 1015, 2004 T.C.M. (RIA) ¶ 2004-046 at 322. II. Statutes: 1. Internal Revenue Code When citing to the current Code, do not cite to the U.S.C., and do not include the year. Cite using the section symbol. When citing to multiple sections, use two section symbols. When citing to multiple subsections within a single section, use only one section symbol: I.R.C. § 61. I.R.C. § 368(a)(2)(D). I.R.C. §§ 55–59 or I.R.C. §§ 55 to 59. I.R.C. §§ 1, 11. I.R.C. §§ 117(d), 127(c). I.R.C. § 368(a), (c). I.R.C. § 162(a)–(d). When citing to the Internal Revenue Code of 1954 or the Internal Revenue Code of 1939, include "(1954)" or “(1939)” in the citation, as appropriate: I.R.C. § 341 (1954). I.R.C. § 212 (1939). Note: “Id.” is never used to refer to a Code section. It may be used with other statutes and regulations. 2. Other Federal Statutes and State Statutes When cite-checking other statutory material, it is imperative that you include the year of the statute. The appropriate year is obtained from the statutory code books, not from Westlaw or Lexis. The United States Code is available in the Williams Reading Room. State codes are available on the fourth floor. You must make copies of both the statute being cited and the book’s title page (so as to have the appropriate year recorded). 3. Revenue Acts and Tax Reform Acts When citing to an act, give the official name, Public Law Number (or chapter number if enacted before 1957), and Statutes-at-Large citation. Include a pinpoint cite for both the Public Law and the Statutes-at-Large. Do not include the year in a parenthetical if it appears in the official name. Do not include parenthetical information regarding the codification of the act in Title 26 of the United States Code. Technical and Miscellaneous Revenue Act of 1988, Pub. L. No. 100-647, 102 Stat. 3342. Revenue Act of 1951, ch. 521, 65 Stat. 452. Omnibus Budget Reconciliation Act of 1989, Pub. L. No. 101-239, § 7403, 103 Stat. 2106, 2358-61. Foreign Investment in Real Property Tax Act, Pub. L. No. 96-499, § 112(a), 94 Stat. 2599, 2682-87 (1980). III. Administrative and Executive Materials: 1. Treasury Regulations Cite regulations and temporary regulations to themselves. Cite proposed regulations to the Federal Register. Reg. § 1.61-1(a). Reg. § 20.2031-2. Temp. Reg. § 1.61-1T(a). Temp. Reg. § 1.469-2T(f)(5). Prop. Reg. § 1.482-1(d), 31 Fed. Reg. 10,394 (1978). Prop. Reg. § 1.246-5, 58 Fed. Reg. 1000 (1997). The following is a citation to a single section: Reg. § 1.61-1(a), -1(b). The following are citations to multiple sections: Reg. §§ 1.61-1(c), -2(d). Reg. §§ 1.61-1 to -2(f). Reg. § 1.61-1(a)(1), -1(a)(3), -1(b). Cite examples in regulations as follows: Reg. § 1.162-27(c)(6), Ex. (1). Reg. § 1.351-1(c)(6), Ex. (6). Regulations promulgated earlier than 1954 were numbered according to the chapter of the Code of Federal Regulations in which they fell. Reg. 108, § 86.100 (1943). In textual sentences. Write out and capitalize “Proposed,” “Temporary,” and “Regulation” when referring to a specific regulation, but do not capitalize when referring to regulations generally. Write out, but do not capitalize, “section.” Examples: Temporary Regulation section 1.469-2T(c)(7)(vi) and (d)(2)(xi) concerns the treatment of casualty and theft losses. The regulations Congress enacted in 1984 were very controversial. 2. Acquiescences and Nonacquiescences Nonacquiescences should always be cited. Acquiescences need only be cited when the author regards them as significant. Parallel cite to the CUMULATIVE BULLETIN (C.B.). Do not include the date if it is the same as the volume number of the CUMULATIVE BULLETIN. No comma follows "acq." or "nonacq." Campbell v. Commissioner, 958 F.2d 53 (4th Cir. 1992), nonacq. 1993-1 C.B. 1. Gustafson v. Commissioner, 97 T.C. 85, acq. 1992-2 C.B. 1. Estate of Adkins v. Commissioner, 34 T.C. 67, acq. in part 1989-2 C.B. 9. 3. Actions on Decisions Actions on Decision may be cited to themselves but are more commonly included in the citation as subsequent history. Do not include the year of the action on decision if it is the same year as the case. If cited to itself, cite to the I.R.B. if therein; otherwise, include full date. Cited as subsequent history: Frewing v. Commissioner, 95 T.C. 987 (1993), action on decision 1994-069 (Aug. 18, 1994). Frewing v. Commissioner, 95 T.C. 987 (1994), action on decision 1994-069. Cited to itself: A.O.D. 1993-069, 1998-41 I.R.B. 24. If note in the I.R.B.: A.O.D. 1993-069 (Aug. 18, 1994). 4. Treasury Decisions Cite a treasury decision when referring to the treasury decision itself or when comparing two or more treasury decisions. Cite to the Cumulative Bulletin (C.B.) or the Internal Revenue Bulletin (I.R.B.) in that order of preference. T.D. 8477, 1993-1 C.B. 82. T.D. 8478, 1993-13 I.R.B. 6. 5. Revenue Rulings Cite to the C.B. or the I.R.B. in that order of preference. Note that the entire year is used as opposed to the last two digits of the year. Rev. Rul. 1990-57, 1990-1 C.B. 142. Rev. Rul. 1991-42, 1991-37 I.R.B. 6. 6. Revenue Procedures Cite to the C.B. or the I.R.B. in that order of preference. Note that the entire year is used as opposed to the last two digits of the year. Rev. Proc. 1991-38, 1991-2 C.B. 692. Rev. Proc. 1993-27, 1993-24 I.R.B. 63. 7. Private Letter Rulings Private Letter Rulings are cited to themselves. The full date of the ruling should be included in the citation. Note that citations to Private Letter Rulings should include hyphens. The original source will not have included them. P.L.R. 1991-08-030 (Nov. 27, 1990). When citing to multiple, consecutive private letter rulings decided on the same day, cite as follows: P.L.R. 1991-08-030-6 (Nov. 27, 1990). 8. Technical Advice Memoranda Technical advice memoranda are cited to themselves. The date should be included. T.A.M. 1986-25-003 (Feb. 28, 1986). When citing to multiple, consecutive technical advice memoranda decided on the same day, cite as follows: T.A.M. 1986-25-003-7 (Feb. 28, 1986). 9. Litigation Guideline Memoranda Cite Litigation Guideline Memoranda to themselves. The full date of the ruling should be included in the citation. Litigation Guideline Memorandum 2000-15-037 (Apr. 14, 2000). 10. Chief Counsel Memoranda (formerly General Counsel Memoranda) Cite pre-1953 memoranda to the C.B. Cite more recent memoranda to themselves: G.C.M. 26,993, 1951-2 C.B. 54. G.C.M. 38,814 (Dec. 23, 1981). G.C.M. 1034 (Mar. 12, 1997). 11. Chief Counsel Advice Cite Chief Counsel Advisories to themselves. The full date of the ruling should be included in the citation. C.C.A. 2000-01-007 (Jan. 7, 2000). When citing to multiple, consecutive Chief Counsel Advisories decided on the same day, cite as follows: C.C.A. 2000-01-007-9 (Jan. 7, 2000). 12. I.R.S. News Releases The Service often releases general information to the public without publishing it in the CUMULATIVE BULLETIN (C.B.). Cite such releases to a commercial tax service: the UNITED STATES TAX REPORTER (U.S. Tax Rep. (RIA)) or the STANDARD FEDERAL TAX REPORTER (Stand. Fed. Tax Rep. (CCH)), if therein. Citation to these services includes the type of release, the serial number (if applicable) or publication date, the volume, and page number. IR-News Rel. 1996-11, 32 U.S. Tax Rep. (RIA) ¶ 67,097. IR-News Rel. 1995-34, 16 Stand. Fed. Tax Rep. (CCH) ¶ 88,098. 13. I.R.S. Notices Cite to the C.B. or the I.R.B. in that order of preference.: Notice 1991-20, 1991-2 C.B. 614. Notice 1993-56, 1993-35 I.R.B. 21. 14. I.R.S. Legal Memoranda Cite the I.R.S. Legal Memoranda to themselves: I.R.S. Legal Memorandum 2000-19-009 (Feb. 7, 2000). 15. Announcements Cite to the C.B. if therein, otherwise to the I.R.B.: Announcement 1993-136, 1993-33 C.B. 19. Announcement 1993-136, 1993-45 I.R.B. 24. 16. Internal Revenue Manual Cite to Commerce Clearing House (CCH), if therein, otherwise to the official Service manual itself. CCH is cited by volume, subject matter, publication, paragraph number, and page. I.R.M. is cited with the part number, chapter number, section number, and subsection number. All of these numbers are cited in an uninterrupted string. Sub- subsection numbers are separated by a period and the sub-sub-subsection numbers are enclosed in parenthesis: 8 Filing Requirements, I.R.M. (CCH), ¶ 8987 at 34,231. I.R.M. 6783.4(16). 17. Staff of the Joint Committee on Taxation STAFF OF J. COMM. ON TAX’N, 94TH CONG., TAX REFORM ACT OF 1976 27 (Comm. Print 1976). IV. Periodical Materials: 1. Tax Periodicals. The following list provides citation examples for many commonly cited tax periodicals: American Bar Association Tax Section Comm. on Interest Rates, ABA Tax Sec., Committee Reports Interest Rate Agreements in 1991 33 (1992). Arthur L. George & Thomas A. O'Donnell, Foreign Income: Business Operations in the BNA Tax Management Portfolio U.S.S.R., 990 TAX MGMT. PORT. (BNA) A-21 (1991). Bentsen Introduces Own Bill on Simplification, DAILY TAX REP. (BNA), Apr. 1, Daily Tax Report (BNA) 1991, at A-3. Rostenkowski Bill on Simplification, 52 Daily Tax Highlights & Documents HIGHLIGHTS & DOC. 123 (Jan. 12, 1991). Japanese Industrial Base, 76 FED. RES. BULL. Federal Reserve Bulletin 333 (Feb. 1990). In 1979 this periodical changed to a chapter and section format. Thus: 34 N.Y.U. ANN. INST. FED. TAX'N 458 (1977). NYU Annual Institute on Federal Taxation David S. Champi, Stimulating Industrial Base with Defense Credits, 46 N.Y.U. ANN. INST. FED. TAX’N § 23.09, at 23-10 (1990). Eugene Whetzel, Ohio: State Tax Commissioner State Tax Notes (Tax Analysts) Clarifies Resident Income Tax Credit, 2 ST. TAX NOTES (TA) 36 (Sept. 9, 1991). Nebraska Reduces Fourth Quarter Fuel Tax State Tax Review (CCH) Rate, ST. TAX REV. (CCH), Sept. 3, 1991, at 1. Foreign Currency Translation, Statement of Statements of the Financial Accounting Financial Accounting Standards No. 52, § 32 Standards Board (Fin. Accounting Standards Bd. 1982). Reimbursements Under New Meal and Lodging Tax Focus (CCH) Per Diems, TAX FOCUS (CCH), Feb. 6, 1990, at 1. The Lexis version of Tax Notes Today does not have page numbers. Thus: Tax Notes Today Closing Agreement on Final Determination Covering Specific Matters, 2000 TAX NOTES TODAY 75-12 (Apr. 7, 2000). John T. Jones, New Zealand Insurance Firms Tax Notes International (Tax Analysts) Lose Revenues, 12 TAX NOTES INT'L (TA) 333 (Jan. 6, 1991). Robert I. Plant & Ellaine E. Tilton, The Pension Reversion Controversy and the “Buck Tax Notes (Tax Analysts) Letter”: Another Round, 26 TAX NOTES (TA) 1147, 1154 (Mar. 18, 1985). Accountant Examines U.K.'s New ‘Simpler' Tax Notes International Weekly News Self-Employment Rules, 2 TAX NOTES INT'L WKLY. (Tax Analysts) NEWS (TA) 23 (Aug. 24, 1991). 2000 TAXDAY, Item J.9 (Nov. 2, 2000). TaxDay Alternative Measures to Replace "Comfort Ruling" Policy, TAXES ON PARADE (CCH), Oct. 9, Taxes on Parade (CCH) 1990, at 1. This periodical is not consecutively paginated. Thus, references to pages should be made by author: Tulane Tax Institute Christine A. Smith, Reorganizations and Recapitalizations, 41st Ann. Tulane Tax Inst., Smith at 13, (1990). 2. Tax Library Services and Loose-leaf Services: Cite as follows: volume number (if applicable), reporter name, publisher, paragraph number. The following list provides citation examples for the most common library services: Estate and Gift Tax Reporter EST. & GIFT (RIA) ¶ 478.2. Federal Taxes 2D 67-3 FED. TAX. 2D (P-H) ¶ 3101. Federal Estate and Gift Tax Reporter EST. & GIFT (CCH) ¶ 1359.66. Standard Federal Tax Reporter (CCH) 67-5 STAND. FED. TAX REP. (CCH) ¶4751.05. State & Local Taxes PA. STATE & LOCAL TAX. (RIA) ¶ 10,020. United States Tax Reporter IR-News Rel. 96-11, 32 U.S. Tax Rep. (RIA) ¶ 67,097. V. Tax Treaties The format for citing a tax treaty is as follows: title, signing date (not the effective date), parties, subdivision or article (if applicable), source. Country names should be abbreviated according to Bluebook table T10.3. Cite to UNITED STATES TREATIES AND OTHER INTERNATIONAL AGREEMENTS (U.S.T.), if therein, otherwise to TREATIES AND OTHER INTERNATIONAL ACTS SERIES (T.I.A.S.), if therein, otherwise to Statutes-at-Large. When possible, a parallel cite should be given to the CUMULATIVE BULLETIN (C.B.) and TAX TREATIES (CCH). Income Tax Convention, Aug. 24, 1980, U.S.-Egypt, art. 12(7), 33 U.S.T. 1809. Treaty of Amity & Economic Relations, Apr. 3, 1961, U.S.-Vietnam, 12 U.S.T. 1703, T.I.A.S. No. 4890. Isthmian Canal Convention, Nov. 18, 1903, U.S.-Pan., 33 Stat. 2234. Protocol with Respect to Income Tax Treaty, Feb. 22, 1990, U.S.- Spain, TAX TREATIES (CCH) ¶ 8404. Income Tax Treaty, Dec. 18, 1992, U.S.-Neth., TAX TREATIES (CCH) ¶ 6603.31. Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, U.S.-U.K., art. II(1)(l), Apr. 16, 1945, 60 Stat. 1377.
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