Writing Style Manual 2014 2015 FINAL
Writing Style Manual 2014 2015 FINAL
TAX
LAWYER
Citation
and
Style
Manual
2014-2015
TABLE
OF
CONTENTS
Source
Collection
...................................................................................................................................................
3
I.
Introduction
..................................................................................................................................................
4
II.
Special
Source
Requirements
..............................................................................................................
4
III.
Source
Collection
Tips
...........................................................................................................................
5
Source
Verification
&
Citation
Editing
......................................................................................................
6
I.
Introduction
..................................................................................................................................................
7
II.
Source
Verification
...................................................................................................................................
7
III.
Citation
Editing
.........................................................................................................................................
7
IV.
Citation
Editing
Guide
............................................................................................................................
8
A.
Standard
Footnote
Formatting
.......................................................................................................
8
B.
Footnote
Cross-References
..............................................................................................................
8
C.
Case
Citations
.........................................................................................................................................
9
D.
Statutory
Citations
.............................................................................................................................
12
E.
Administrative
&
Executive
Pronouncement
Citations
.....................................................
13
F.
Common
Tax
Periodicals
................................................................................................................
19
G.
Tax
Treaties
..........................................................................................................................................
20
H.
Internet
Citations
...................................................................................................................................
21
I.
Attribution
Footnotes
........................................................................................................................
21
Textual
Editing
......................................................................................................................................................
23
I.
Introduction
................................................................................................................................................
24
II.
Text
Formatting
.......................................................................................................................................
24
III.
Textual
Style
Rules
................................................................................................................................
26
A.
The
Code,
The
Service,
and
Regulations
..................................................................................
26
B.
Common
Punctuation
Errors
........................................................................................................
27
C.
Numbers
.................................................................................................................................................
29
D.
Miscellaneous
.......................................................................................................................................
30
IV.
Abstracts
...................................................................................................................................................
30
SOURCE
COLLECTION
I.
Introduction
As
a
Staff
Member
of
The
Tax
Lawyer,
you
are
an
essential
part
of
our
editing
process.
When
we
edit
articles
for
publication,
our
primary
goal
is
to
verify
the
integrity
of
the
authors
citations.
You
are
absolutely
critical
to
our
achievement
of
that
goal.
For
each
Bluebooking
assignment,
you
will
be
assigned
several
footnotes.
Once
you
have
received
your
footnote
assignment,
you
will
need
to
first
locate
the
sources
referenced
in
each
of
your
footnotes
and
download
them
to
your
computer
(source
collect).
If
the
sources
are
books
or
are
otherwise
required
to
be
in
paper
form,
you
can
use
the
Librarys
large
scanners
in
order
to
scan
and
upload
the
relevant
pages
to
the
online
management
system
in
pdf.
It
is
important
that
you
begin
source
collection
early
in
the
assignment
period.
Some
sources
may
be
difficult
to
find
and
may
require
borrowing
books
from
other
libraries
or
other
special
effort.
In
the
event
that
you
cannot
find
a
source
after
going
through
the
collection
efforts
discussed
in
Part
III
below,
please
alert
your
Senior
Editor
as
soon
as
possible.
II.
Special
Source
Requirements
In
general,
you
will
only
be
required
to
locate
a
source
in
its
online
format;
however,
for
the
particular
sources
listed
below,
you
will
need
to
fulfill
special
sourcing
requirements
in
order
to
obtain
the
proper
pagination
for
citation.
1.
Tax
Court
Memorandum
Decisions
For
Tax
Court
Memorandum
Decisions,
you
will
be
required
to
use
parallel
citations.
The
RIA
Citator
is
available
online
through
Checkpoint;
however,
you
also
need
to
cite
to
the
CCH
Reporter,
which
must
be
accessed
through
the
Bloomberg
Law
website
(starred
pages
included).
Note
that
Intelliconnect
does
NOT
include
the
page
numbers.
In
order
to
get
a
Bloomberg
Law
account,
you
must
email
Beth
Goldfinger
([email protected]).
Once
you
are
in
the
Bloomberg
site,
search
xxx
T.C.M.
(CCH)
yyyy
in
the
search
bar,
and
you
will
be
directed
to
the
case.
2.
Statutes
To
ensure
that
the
actual
year
of
the
official
reporter
is
reflected
in
a
statute
citation,
you
will
be
required
to
use
the
paper
copy
of
a
state
or
federal
statute
compilation
as
is
available
in
the
library.
Be
sure
that
you
also
upload
the
compilations
title
page
so
that
the
year
is
confirmed.
In
the
event
that
a
code
compilation
is
not
available,
please
notify
your
Senior
Editor
immediately
so
that
he
or
she
may
request
a
paper
copy
through
the
Interlibrary
Loan
service.
Note
that
any
citations
to
the
Internal
Revenue
Code
do
not
require
citation
of
a
year
and
therefore
can
be
collected
in
Westlaw
or
Lexis
format.
3.
Legislative
History
Materials
from
1970-1990
4
Because
the
availability
of
these
materials
online
is
sporadic,
it
is
likely
that
you
will
need
to
retrieve
any
legislative
history
from
this
period
in
hard
copy
in
the
library.
Please
work
with
a
reference
librarian
in
the
event
that
you
are
assigned
a
footnote
that
requires
use
of
legislative
history
materials
from
this
time
period.
III.
Source
Collection
Tips
1.
Westlaw
Tax
Tab:
In
order
to
facilitate
your
research
of
tax-specific
sources,
you
can
add
a
Tax
tab
to
your
Westlaw
home
page
by
clicking
Add
a
Tab
and
then
navigating
to
the
Westlaw
tabs
and
the
topical
tabs
they
have
created.
In
WestlawNext,
there
is
a
tax-specific
research
category
that
can
be
accessed
by
clicking
the
Topics
tab
on
the
home
page
and
then
clicking
Tax.
2.
Tax-Specific
Databases
(RIA
&
CCH):
Some
cases
are
only
available
through
the
RIA
or
CCH
websites.
These
can
be
accessed
by
navigating
to
the
Georgetown
Law
Library
website,
clicking
on
research
guides,
and
scrolling
down
to
Tax.
CCH
sources
can
be
accessed
through
Bloomberg
Law,
and
RIA
sources
can
be
accessed
through
the
Checkpoint
database.
Note
that
you
will
be
required
to
sign
up
for
a
Bloomberg
Law
account
for
access.
3.
Legislative
Materials:
Legislative
history
materials
are
generally
available
on
ProQuest
Congressional,
which
is
listed
under
the
Frequently
Used
Databases
link
on
the
Georgetown
Law
Library
website.
From
the
home
page,
you
can
search
for
bills
by
public
law
or
bill
number
and
navigate
to
historical
materials
from
there.
You
can
also
use
an
advanced
search
to
find
a
specific
house
report
or
other
historical
material
by
its
citation.
4.
Journal
Articles:
Journal
articles
can
be
collected
using
a
variety
of
sources.
Both
Lexis
and
Westlaw
have
journal
databases
and
can
often
retrieve
articles
from
the
citation
alone.
If
neither
Lexis
nor
Westlaw
has
access
to
the
journal,
the
library
provides
an
E-Journal
Finder
under
its
GULLiver
catalog.
Other
databases
that
can
be
accessed
from
the
librarys
main
page
that
can
be
helpful
for
finding
such
articles
include
HeinOnline
and
JSTOR.
5.
InterLibrary
Loan:
Books
can
be
loaned
from
other
libraries
directly
to
The
Tax
Lawyer
office.
This,
however,
must
be
coordinated
through
your
Senior
Editor
and
must
be
requested
at
the
beginning
of
the
assignment
period.
6.
Library
Resources:
In
the
event
that
you
ever
have
difficulty
locating
sources,
it
is
encouraged
that
you
use
the
Live
Help
link
provided
on
the
Librarys
homepage
or
visit
the
Reference
Desk
in
Williams
Library.
In
addition,
Jason
Zarin,
the
tax-specific
reference
librarian
can
be
reached
at
[email protected].
SOURCE
VERIFICATION
&
CITATION
EDITING
I.
Introduction
This
Part
discusses
the
nature
of
source
verification
and
citation
checking
and
editing,
which
will
compose
the
large
majority
of
your
assignments.
Bear
in
mind
that
you
will
get
better
with
both
of
these
over
time,
and
that
as
your
assignments
progress,
you
will
be
able
to
remember
and
implement
tax-specific
citations
by
memory.
Nevertheless,
remember
to
always
consult
the
reference
books
whenever
you
are
unsure.
In
addition,
your
Senior
Editor
will
send
out
group
feedback
and
the
Managing
Editor
will
maintain
and
update
a
list
of
common
citation
editing
errors
after
each
assignment,
so
be
sure
to
pay
attention
to
ensure
that
you
do
not
consistently
make
the
same
mistakes.
II.
Source
Verification
Once
you
have
located
a
source,
the
next
step
is
to
read
the
cited
material
within
that
source
and
to
ensure
that
it
supports
what
the
author
has
written
in
his
or
her
Article
or
Note.
This
should
be
a
multi-step
process:
(1)
Ask
yourself,
does
this
material
reflect
what
the
author
has
written?
Highlight
the
portion
of
the
page
or
case
that
supports
the
authors
statement
in
your
electronic
document
or
pdf.
In
the
event
that
you
are
not
completely
certain
whether
the
statement
you
have
found
supports
the
author,
flag
the
issue
and
alert
your
Senior
Editor.
(2)
Were
the
pages
provided
correct?
Does
the
source
verify
the
information
better
or
more
closely
on
a
different
page?
If
so,
change
the
pincite
to
reflect
the
correct
page
or
page
range.
Where
an
author
has
cited
to
a
case
to
support
a
specific
proposition,
a
pincite
should
always
be
included.
(3)
Check
for
plagiarism.
Any
five
or
more
words
that
are
taken
verbatim
from
the
text
should
be
placed
in
quotes.
Please
flag
any
possible
issues
for
your
Senior
Editor
and
insert
quotes
in
the
text
where
appropriate
to
prevent
plagiarism.
Using
the
checklist
that
has
been
provided
should
help
guide
you
through
these
steps
and
help
you
to
understand
once
a
source
has
been
properly
verified.
All
source
documents
MUST
be
uploaded
to
Box.
III.
Citation
Editing
Editing
citations
will
take
up
the
vast
majority
of
your
time
in
each
assignment.
The
Tax
Lawyer
follows
three
different
sources
for
editing:
(1)
The
Citation
and
Style
Manual
(a.k.a.
The
Crimson
Guide),
(2)
The
Bluebook:
A
Uniform
System
of
Citation
(Bluebook)
(Columbia
Law
Review
Assn
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
Assn,
12th
ed.
2011).
Where
they
conflict,
the
Crimson
Guide
will
supersede
the
rules
of
the
Bluebook,
which
will
in
turn
supersede
any
conflicting
rules
in
the
TMOUS.
7
Below,
Part
IV
describes
the
special
citation
rules
that
The
Tax
Lawyer
follows
for
footnotes.
The
final
section
regarding
Textual
Editing
will
discuss
textual
style
and
formatting
rules.
You
will
still
need
to
refer
to
these
in
the
event
that
an
author
has
included
an
explanatory
footnote;
however,
they
will
not
concern
the
majority
of
your
editing
responsibilities
as
a
staff
member.
IV.
Citation
Editing
Guide
A.
Standard
Footnote
Formatting
(1)
All
footnotes
should
be
in
Courier
New
10
point
font.
(2)
Footnotes
must
be
indented
by
a
single
tab
from
the
left
margin.
In
the
event
that
a
footnote
is
greater
than
one
line,
subsequent
lines
are
not
indented
and
should
be
flush
with
the
left
margin.
(3)
There
should
be
no
space
between
the
superscript
numeral
and
the
first
letter
of
the
footnote.
Because
Microsoft
Word
inserts
such
a
space
automatically,
you
will
have
to
delete
it
manually.
Example:
1Jones
v.
Smith,
2
U.S.
387,
390
(1990)
(holding
that
students
who
are
on
THE
TAX
LAWYER
are
happier
than
those
students
who
are
not).
NOT
2
Jones
v.
Smith,
2
U.S.
387,
390
(1990)
(holding
that
students
who
are
on
THE
TAX
LAWYER
are
happier
than
those
students
who
are
not).
(4)
Footnotes
should
generally
go
at
the
end
of
a
sentence,
unless
there
are
pinpoint
citations
for
different
propositions
within
a
single
sentence.
Where
a
case
is
named
within
a
sentence,
it
is
not
necessary
to
include
a
footnote
immediately
after
that
case
name,
but
instead
it
should
be
placed
at
the
end
of
the
sentence.
B.
Footnote
Cross-References
(1)
Footnotes
that
cross-reference
other
footnotes
within
the
work
through
the
use
of
supra
should
not
be
created
by
typing
out
the
cross-reference
manually.
Instead,
a
hyperlink
should
be
inserted
to
reference
the
other
footnote.
This
can
be
accomplished
in
Microsoft
Word
by
clicking
Insert,
Reference,
and
then
Cross-Reference.
C.
Case
Citations
(1)
General
Formatting:
Case
names
are
not
italicized
when
cited
in
full
citation
sentences
but
are
italicized
in
a
short
citation.
Example:
Simpson
v.
Jones,
73
F.2d
849,
854
(2d
Cir.
2001).
NOT
Simpson
v.
Jones,
73
F.2d
849,
854
(2d
Cir.
2001).
BUT
Simpson,
73
F.2d
at
856.
(2)
The
Commissioner
and
United
States:
Do
not
abbreviate
Commissioner
or
United
States
when
they
are
parties
to
a
case.
This
applies
to
both
the
IRS
Commissioner
and
any
state
tax
commissioners
that
may
be
parties.
Example:
Jenkins
v.
Commissioner,
84
F.3d
222,
224
(8th
Cir.
1981).
NOT
Jenkins
v.
Commr,
84
F.3d
222,
224
(8th
Cir.
1981).
(3)
Citations
for
Tax
Decisions
of
all
Federal
courts,
including
Federal
Courts
of
Appeals,
Federal
District
Courts,
the
Court
of
Federal
Claims
(Fed.
Cl.),
and
Bankruptcy
Courts
(B.R.):
Cite
to
the
Federal
Reporter,
if
published
therein,
according
to
standard
bluebook
rules;
if
not,
use
a
parallel
cite
to
the
United
States
Tax
Cases
and
the
American
Federal
Tax
Reports
as
illustrated
below.
If
the
Bankruptcy
Court
decision
is
likewise
not
published
in
the
U.S.T.C.
or
A.F.T.R.,
cite
to
the
Bankruptcy
Law
Reporter.
Examples:
Charlesworth
v.
Commissioner,
982
U.S.T.C.
55,543,
63
A.F.T.R.2d
1620
(1st
Cir.
1990).
In
re
Imperial
Corp.,
199091
Bankr.
L.
Rep.
(CCH)
74,096
(Bankr.
S.D.
Cal.
1991).
Note
that
the
U.S.T.C.
is
always
cited
before
the
A.F.T.R.
Pinpoint
citations
in
the
U.S.T.C.
should
be
to
the
page
number
on
which
the
information
appears,
even
though
the
initial
citation
is
to
the
cases
paragraph
number.
Never
include
the
last
two
digits
of
the
case
year
before
the
page
9
number
included
in
the
A.F.T.R.
citation,
even
if
the
actual
A.F.T.R.
edition
includes
these
numbers.
To
form
the
short
citation
using
these
parallel
citations,
shorten
only
the
case
name
and
include
all
other
information
with
the
exception
of
the
starting
page
number
for
the
A.F.T.R.;
however,
when
using
the
Id.
form,
you
may
also
omit
the
reporter
and
paragraph
information
for
the
U.S.T.C.
Examples:
United
States
v.
Goetzl,
742
U.S.T.C.
9787,
at
10,950,
34
A.F.T.R.2d
6142,
6145
(7th
Cir.
1974).
Goetzl,
742
U.S.T.C.
9787
at
10,950,
34
A.F.T.R.2d
at
6145.
Id.
at
10,951,
34
A.F.T.R.2d
at
6146.
(4)
Decisions
of
the
Board
of
Tax
Appeals:
Cite
to
the
Board
of
Tax
Appeals
Reports
as
illustrated
below.
Example:
Thatcher
v.
Commissioner,
45
B.T.A.
64,
66
(1941).
(5)
Memorandum
Decisions
of
the
Board
of
Tax
Appeals:
Cite
to
the
Prentice-Hall
Board
of
Tax
Appeals
Memorandum
Decisions,
as
illustrated
below.
Example:
Clinton
v.
Commissioner,
7
B.T.A.
Mem.
Dec.
(P-H)
54,332
(1939).
(6)
Decisions
of
the
Tax
Court:
Cite
to
the
Tax
Court
of
the
United
States
Reports
(T.C.),
but
if
it
is
not
reported
therein,
use
a
parallel
citation
to
the
Tax
Court
Reporter:
Regular
Decisions
(T.C.R.
(CCH)
Dec.)
and
Tax
Court
Reported
Decisions
(T.C.R.
Dec.
(RIA))
as
illustrated
below.
Example:
Peat
Oil
&
Gas
Assoc.
v.
Commissioner,
100
T.C.
271,
278
(1993).
Churchill
Downs,
Inc.
v.
Commissioner,
2000
T.C.R.
(CCH)
Dec.
54,059
at
4327,
115
T.C.R.
Dec.
(RIA)
115,20
at
170.
To
write
a
short
citation
of
the
CCH
and
RIA
dual
citation,
simply
shorten
the
case
name
and
include
the
pinpoint
citation
information
as
opposed
to
the
starting
page
numbers
for
the
CCH
reporter
ONLY.
10
Example:
Churchill
Downs,
2000
T.C.R.
(CCH)
Dec.
at
4327,
115
T.C.R.
Dec.
(RIA)
115,20
at
170.
To
add
a
pinpoint
citation
to
a
regular
decision
of
the
Tax
Court
when
using
Id.,
Drop
all
information
about
the
CCH
reporter
except
for
the
pinpoint
citation
and
maintain
the
citation
for
the
RIA
reporter.
Example:
Id.
at
4327,
115
T.C.R.
Dec.
(RIA)
115.20
at
171.
(7)
Tax
Court
Memorandum
Decisions:
Because
Tax
Court
Memorandum
Decisions
are
not
reported
in
the
Tax
Court
of
the
United
States
Reports,
you
must
use
the
parallel
citation
to
the
respective
CCH
and
RIA
Reporters:
CCH
Tax
Court
Memorandum
Decisions
(T.C.M.
(CCH))
and
RIA
Tax
Court
Memorandum
Decisions
(T.C.M.
(RIA)).
The
short
citation
and
Id.
citations
are
formed
identically
to
that
for
regular
decisions
of
the
Tax
Court.
Full
citations
should
always
have
a
comma
after
the
paragraph
for
the
RIA
or
P-H
source.
Example:
Milner
v.
Commissioner,
65
T.C.M.
(CCH)
2085,
2087,
1993
T.C.M.
(RIA)
93,091,
at
420.
Milner,
65
T.C.M.
(CCH)
at
2087,
1993
T.C.M.
(RIA)
93,091
at
420.
After
2000,
RIA
began
labeling
its
paragraphs
to
include
the
volume
number
(the
year
of
publication).
When
writing
the
paragraph
number,
include
the
year
again.
Example:
Hillgren
v.
Commissioner,
87
T.C.M.
(CCH)
1008,
1115,
2004
T.C.M.
(RIA)
2004046,
at
322.
Note
that
the
RIA
Reporter
was
previously
published
by
Prentice-Hall.
In
the
event
that
you
find
yourself
using
the
Prentice-Hall
reporter,
which
is
most
likely
if
the
case
is
from
before
1993,
substitute
P-H
for
RIA
in
the
parentheses.
In
addition,
because
there
was
no
year
of
publication
provided
in
the
RIA/P-H
volume
number,
you
will
have
to
add
the
year
of
publication
to
the
end
of
the
citation.
Example:
Barbour
v.
Commissioner,
3
T.C.M.
(CCH)
216,
220,
T.C.M.
(P-H)
44,073,
at
501
(1944).
(8)
The
Internal
Revenue
Service
in
Footnote
Sentences:
When
the
Internal
Revenue
Service
is
referenced
in
an
explanatory
footnote
or
in
the
text,
it
should
always
be
identified
as
11
the
Service.
The
Internal
Revenue
Service
should
NOT
be
referenced
as
the
IRS
unless
the
abbreviation
IRS
appears
in
a
case
name,
document
title,
or
other
such
office
or
committee
title.
D.
Statutory
Citations
(1)
Internal
Revenue
Code
Citations:
If
you
are
citing
to
the
current
edition
of
the
Code,
use
the
abbreviation
I.R.C.
and
provide
only
the
section
number,
using
regular
Bluebook
rules
for
numbering.
Example:
I.R.C.
61.
I.R.C.
5559.
I.R.C.
368(a),
(c).
DO
NOT
use
Id.
when
referring
to
the
Internal
Revenue
Code;
however,
you
may
use
a
section
symbol
followed
by
the
appropriate
section
number
as
a
short
citation
if
the
section
has
been
cited
at
least
5
footnotes
above.
Example:
1I.R.C.
897(f).
2
897(e).
NOT
1I.R.C.
897(f).
2Id.
at
897(e).
If
you
are
citing
to
a
previous
edition
of
the
Code
(1954
or
1939),
indicate
to
the
reader
that
you
are
doing
so
by
including
the
year
in
parentheses
after
the
regular
citation.
Example:
I.R.C.
341
(1954).
(2)
Federal
and
State
Statutes:
Follow
appropriate
bluebook
form
under
Rule
12
and
Table
1.
Remember,
you
must
use
the
hard
copy
of
the
Code
to
verify
the
year
of
the
Code
used.
(3)
Named
Acts:
Form
the
citation
for
ALL
named
acts
such
as
Revenue
Acts,
Tax
Reform
Acts,
and
Budget
Reconciliation
Acts
by
including
BOTH
the
Public
Law
citation
and
the
Statutes-at-
Large
citation.
Never
include
parenthetical
information
regarding
the
codification
of
the
act
in
Title
26.
12
Example:
Foreign
Investment
in
Real
Property
Tax
Act,
Pub.
L.
No.
96499,
112(a),
94
Stat.
2599,
268287
(1980).
NOT
Foreign
Investment
in
Real
Property
Tax
Act,
Pub.
L.
No.
96499,
112(a),
94
Stat.
2599,
268287
(1980)(codified
at
26
U.S.C.
897).
If
the
year
the
act
was
enacted
is
included
in
its
name,
the
parenthetical
indicating
the
year
of
enactment
should
be
omitted.
Example:
Technical
and
Miscellaneous
Revenue
Act
of
1988,
Pub.
L.
No.
100647,
202,
102
Stat.
3342,
335051.
If
the
act
was
enacted
before
1957,
then
there
will
be
no
Public
Law
number.
Add
a
parallel
citation
to
the
relevant
chapter
number
instead.
Example:
Revenue
Act
of
1951,
ch.
521,
802,
65
Stat.
452,
455.
(4)
The
Internal
Revenue
Code
in
Footnote
Sentences:
When
an
author
is
discussing
the
Internal
Revenue
Code
in
a
footnote
sentence,
as
well
as
a
textual
sentence,
it
should
always
be
referred
to
as
the
Code.
However,
if
the
Code
is
being
discussed
in
close
conjunction
with
the
Bankruptcy
Code
or
other
such
Code,
it
may
be
necessary
to
differentiate
the
two
by
labeling
them
as
the
Internal
Revenue
Code
and
the
Bankruptcy
Code,
respectively.
E.
Administrative
&
Executive
Pronouncement
Citations
(1)
Regular
&
Temporary
Treasury
Regulations:
Cite
using
the
format
of
Reg.
or
Temp.
Reg.
followed
by
the
appropriate
section
number
as
illustrated
below.
Example:
Reg.
1.611(a).
Temp.
Reg.
1.4692T(f)(5).
To
cite
to
multiple
subsections
of
the
regulation,
include
a
second
section
sign
if
there
are
only
two
subsections
listed.
If
there
are
more
than
two
subsections
listed,
a
single
section
sign
will
be
sufficient.
Hyphens,
not
en-dashes,
should
be
used
in
Regulations
and
Revenue
Rulings.
When
discussing
a
range,
use
to
when
necessary
for
clarity.
13
Example:
Reg.
1.611(c),
2(d).
Reg.
1.611(a)(1),
1(a)(3),
1(b).
Reg.
1.611
to
2(f).
To
provide
a
pinpoint
citation
to
an
Example
within
a
regulation,
use
the
citation
format
provided
above,
followed
by
Ex.
And
the
example
number
in
parentheses.
Example:
Reg.
1.3511(c)(6),
Ex.
(6).
If
the
regulation
was
promulgated
prior
to
1954,
the
section
will
be
numbered
according
to
the
chapter
of
the
CFR
in
which
it
fell,
as
opposed
to
corresponding
to
the
relevant
Code
section.
Simply
insert
the
regulation
number
and
section
that
is
provided
as
well
as
the
year
into
the
format
used
regularly.
Example:
Reg.
108,
86.100
(1943).
(2)
Proposed
Treasury
Regulations:
In
addition
to
providing
the
abbreviation
Prop.
Reg.
and
the
appropriate
section
number,
also
include
a
citation
to
the
Federal
Register
where
the
Proposed
Regulation
was
initially
published.
All
other
citation
rules
pertaining
the
regulations
discussed
in
(1)
apply.
Example:
Prop.
Reg.
1.4821(d),
31
Fed.
Reg.
10,394
(1978).
(3)
Treasury
Regulations
in
Footnote
Sentences:
When
discussing
a
particular
regulation
in
a
footnote
sentence,
that
regulation
should
be
referred
to
as
the
Proposed
Regulation,
the
Temporary
Regulation,
or
the
Regulation,
accordingly.
References
to
regulations
in
general
do
not
require
capitalization.
If
referring
to
a
particular
section
number
of
the
regulation,
do
not
use
the
section
symbol,
but
use
the
word
section
in
lower
case.
Example:
1Temporary
Regulation
sections
1.4692T(c)(7)(vi)
and
(d)(2)(xi)
concern
the
treatment
of
casualty
and
theft
losses.
14
(4)
Acquiescences
and
Nonacquiescences:
IRS
nonacquiescences
to
case
law
should
ALWAYS
be
cited
following
a
citation
to
the
relevant
case.
Acquiescences
should
only
be
cited
if
the
author
regards
them
as
significant.
These
citations
can
be
made
using
a
citation
to
the
Cumulative
Bulletin
(C.B.)
after
the
italicized
signifier
of
nonacq.
or
acq.,
respectively.
Example:
Campbell
v.
Commissioner,
958
F.2d
53
(4th
Cir.
1992),
nonacq.
19931
C.B.
1.
If
the
year
the
case
was
published
is
the
same
as
that
in
the
volume
number
of
the
Cumulative
Bulletin,
it
is
not
necessary
to
include
the
year
in
the
case
citation
parenthetical.
Example:
Gustafson
v.
Commissioner,
97
T.C.
85,
acq.
19922
C.B.
1.
(5)
Actions
on
Decisions:
Actions
on
Decisions
are
typically
cited
as
subsequent
history
to
a
case,
and
the
action
number
should
immediately
follow
the
case
citation
after
a
comma
and
the
italicized
phrase,
action
on
decision.
Note
that
the
number
of
the
action
on
decision
will
include
the
year
of
its
promulgation.
Example:
Frewing
v.
Commissioner,
95
T.C.
987
(1993),
action
on
decision
1994069
(Aug.
18,
1994).
If
the
action
was
taken
in
the
same
year
as
the
case,
no
date
parenthetical
should
be
included.
Example:
Frewing
v.
Commissioner,
95
T.C.
987
(1994),
action
on
decision
1994069.
The
action
on
decision
can
also
be
cited
to
itself,
using
the
abbreviation
A.O.B.
AND
including
a
parallel
citation
to
the
action
in
the
Internal
Revenue
Bulletin
(I.R.B.).
Example:
A.O.D.
1993069,
199841
I.R.B.
24.
In
the
event
that
the
action
on
decision
is
not
included
in
the
I.R.B.,
omit
the
parallel
citation,
and
add
a
parenthetical
including
the
exact
date
of
publication.
Example:
A.O.D.
1993069
(Aug.
18,
1994).
15
(6)
Treasury
Decisions,
Revenue
Rulings,
and
Revenue
Procedures:
To
cite
a
treasury
decision,
include
a
parallel
citation
to
both
the
decision
number
itself,
denoted
using
the
abbreviation
T.D.,
and
its
location
in
the
Cumulative
Bulletin
(C.B.).
If
the
treasury
decision
is
not
included
in
the
Cumulative
Bulletin,
substitute
a
parallel
citation
to
the
Internal
Revenue
Bulletin
(I.R.B.)
instead.
Note
that
the
most
recent
Cumulative
Bulletin
issued
by
the
Service
was
2008-2.
The
Service
has
announced
that
it
will
not
create
new
Cumulative
Bulletins
after
2008-2.
Thus,
beginning
in
2009,
cite
to
the
weekly
Internal
Revenue
Bulletin
(IRB).
Example:
T.D.
8477,
19931
C.B.
82.
T.D.
8478,
199313
I.R.B.
6.
The
same
preference
should
be
followed
for
Revenue
Rulings,
except
the
abbreviation
Rev.
Rul.
should
be
substituted
for
T.D.
Note
that
the
Revenue
Ruling
will
include
the
year
of
promulgation
in
its
numbering
system.
Only
the
final
two
digits
should
be
included
for
rulings
promulgated
prior
to
the
year
2000.
Any
rulings
published
in
2000
and
after
should
include
the
entire
year.
Example:
Rev.
Rul.
9057,
19901
C.B.
142.
Rev.
Rul.
9142,
199137
I.R.B.
6.
BUT
Rev.
Rul.
200168,
20012
C.B.
159.
Likewise,
the
same
preference
should
be
followed
for
Revenue
Procedures,
except
that
the
abbreviation
Rev.
Proc.
should
be
substituted
for
T.D.
Note
that
the
Revenue
Procedure
will
include
the
year
of
its
promulgation
in
its
numbering
system
and
should
follow
the
same
guidelines
as
those
for
Revenue
Rulings.
Example:
Rev.
Proc.
9138,
19912
C.B.
692.
Rev.
Proc.
9327,
199324
I.R.B.
63.
BUT
Rev.
Proc.
200877,
20081
C.B.
128.
16
(7)
Private
Letter
Rulings,
Technical
Advice
Memoranda,
Chief
Counsel
Advice,
and
Field
Service
Advice:
All
of
these
administrative
pronouncements
will
be
cited
to
themselves
and
will
follow
the
same
format
of
Abbrev.
Year-X-X
(Date).
All
similar
administrative
guidance
that
may
not
be
name
here
should
be
conformed
to
this
format.
The
relevant
abbreviations
are
as
follows:
P.L.R.
(Private
Letter
Ruling),
T.A.M.
(Technical
Advice
Memorandum),
C.C.A.
(Chief
Counsel
Advice),
F.S.A.
(Field
Service
Advice).
Be
aware
that
Technical
ASSISTANCE
Memoranda
will
not
be
cited
like
a
T.A.M.
Refer
to
your
Senior
Editor
for
further
guidance
in
the
event
you
are
unclear.
Example:
P.L.R.
201225010
(June
22,
2012).
T.A.M.
198625003
(Feb.
28,
1986).
C.C.A.
200001007
(Jan.
7,
2000).
F.S.A.
200219004
(May
10,
2002).
In
the
event
that
the
labeling
of
the
document
does
not
appear
to
conform
to
the
Year-X-X
format,
you
may
add
a
19
or
a
20
to
the
front
of
the
label
to
clarify
the
year.
The
final
number
in
the
series
will
always
consist
of
only
three
digits
for
the
purposes
of
placing
en-
dashes,
however,
a
letter
will
not
be
considered
a
digit
for
this
purpose.
Example:
T.A.M.
196607114520A
(July
11,
1996).
NOT
T.A.M.
6607114520A
(July
11,
1966).
All
of
the
final
digits
will
count
up
if
decided
on
the
same
day.
If
you
are
citing
to
multiple,
consecutive
rulings,
advice,
or
memoranda
promulgated
on
the
same
day,
do
so
by
including
another
en-dash
and
adding
the
last
digit
of
the
final
ruling
that
you
wish
to
cite.
Example:
T.A.M.
1986250037
(Nov.
27,
1986).
P.L.R.
19910803942
(Feb.
27,
1991).
In
these
examples,
these
would
include
the
memoranda
from
003
to
007
and
the
rulings
from
039
to
042.
17
(8)
Chief
Counsel
Attorney
Memoranda
&
General
Counsel
Memoranda:
These
should
be
cited
to
themselves
if
promulgated
after
1953,
using
the
abbreviations
C.A.M.
and
G.C.M.,
respectively.
Note
that
Chief
Counsel
Attorney
Memoranda
follow
a
different
labeling
system
from
the
General
Counsel
Memoranda.
Always
list
the
numbers
without
a
hyphen
unless
it
is
clear
that
the
initial
digits
indicate
the
year
of
promulgation.
Example:
C.A.M.
2009005
(July
2,
2009).
G.C.M.
38,814
(Dec.
23,
1981).
If
the
General
Counsel
Memorandum
was
promulgated
prior
to
1953,
include
a
parallel
citation
to
the
Cumulative
Bulletin
(C.B.)
and
do
not
include
the
date
of
publication.
Example:
G.C.M.
26,993,
19512
C.B.
54.
(9)
Litigation
Guideline
Memoranda
and
I.R.S.
Legal
Memoranda:
Although
the
citation
formats
for
these
memoranda
are
similar
to
those
for
the
documents
discussed
in
(7)
above,
the
titles
of
these
documents
should
NEVER
be
abbreviated.
All
other
rules
applying
to
memoranda
in
(7)
otherwise
apply.
Example:
Litigation
Guideline
Memorandum
200015037
(Apr.
14,
2000).
I.R.S.
Legal
Memorandum
200019009
(Feb.
7,
2000).
(10)
I.R.S.
News
Releases:
If
not
published
in
the
general
bulletin,
cite
to
EITHER
the
United
States
Tax
Reporter
(U.S.
Tax
Rep.
(RIA))
or
the
Standard
Federal
Tax
Reporter
(Stand.
Fed.
Tax
Rep.
(CCH)).
These
detailed
citations
should
include
the
type
of
release
(typically
IR-News
Rel.),
the
serial
number
or
the
publication
date,
the
volume,
and
the
page
number.
Example:
IR-News
Rel.
199611,
32
U.S.
Tax
Rep.
(RIA)
67,097.
IR-News
Rel.
199534,
16
Stand.
Fed.
Tax
Rep.
(CCH)
88,098.
IR-News
Rel.
May
2,
1982,
20
U.S.
Tax
Rep.
(RIA)
52,520.
(11)
I.R.S.
Notices
&
Announcements:
Like
Revenue
Rulings
and
Revenue
Processes,
these
should
be
cited
to
the
Cumulative
Bulletin
(C.B.),
but
if
not
reported
therein,
they
should
be
cited
to
the
Internal
Revenue
Bulletin
(I.R.B.).
If
published
prior
to
2000,
the
prefix
19
should
be
18
omitted
from
the
Notice
or
Announcement
number,
but
should
not
be
omitted
from
the
C.B.
or
I.R.B.
citation.
Example:
Notice
9120,
19912
C.B.
614.
Notice
9356,
199335
I.R.B.
21.
Announcement
93136,
199333
C.B.
19.
Announcement
200922,
200914
I.R.B.
78.
(12)
Internal
Revenue
Manual:
Citations
to
the
Manual
should
be
to
CCH;
however,
if
it
has
not
been
published
by
CCH,
then
it
should
be
cited
to
itself.
The
CCH
citation
will
include
the
volume
and
subject
matter
as
well
as
a
paragraph
and
page
number
for
a
pincite,
whereas
the
I.R.M.
citation
will
cite
directly
to
the
chapter,
section,
and
subsection
cited
as
a
string
separated
only
by
periods.
Parentheses
should
enclose
any
sub-subsection
numbers.
Example:
8
Filing
Requirements,
I.R.M.
(CCH),
8987
at
34,231.
I.R.M.
6783.4(16).
F.
Common
Tax
Periodicals:
All
citations
to
the
following
periodicals
should
conform
to
the
abbreviations
and
stylistic
characteristics
of
the
table
below:
American
Bar
Association
Tax
Comm.
on
Interest
Rates,
ABA
Tax
Sec.,
Interest
Section
Committee
Reports
Rate
Agreements
in
1991
33
(1992).
Arthur
L.
George
&
Thomas
A.
O'Donnell,
Foreign
Income:
Business
Operations
in
the
U.S.S.R.,
990
TAX
BNA
Tax
Management
Portfolio
MGMT.
PORT.
(BNA)
A-21
(1991).
Bentsen
Introduces
Own
Bill
on
Simplification,
DAILY
Daily
Tax
Report
(BNA)
TAX
REP.
(BNA),
Apr.
1,
1991,
at
A-3.
Daily
Tax
Highlights
&
Rostenkowski
Bill
on
Simplification,
52
HIGHLIGHTS
&
Documents
DOC.
123
(Jan.
12,
1991).
Japanese
Industrial
Base,
76
FED.
RES.
BULL.
333
Federal
Reserve
Bulletin
(Feb.
1990).
In
1979
this
periodical
changed
to
a
chapter
and
section
format.
Thus:
NYU
Annual
Institute
on
34
N.Y.U.
ANN.
INST.
FED.
TAX'N
458
(1977).
Federal
Taxation
David
S.
Champi,
Stimulating
Industrial
Base
with
19
State
Tax
Notes
(Tax
Analysts)
State
Tax
Review
(CCH)
Statements
of
the
Financial
Accounting
Standards
Board
Tax
Focus
(CCH)
Tax
Notes
International
(Tax
Analysts)
Tax
Notes
(Tax
Analysts)
Tax
Notes
International
Weekly
News
(Tax
Analysts)
TaxDay
Taxes
on
Parade
(CCH)
Tulane
Tax
Institute
G.
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.
Cite
to
United
States
Treaties
and
Other
International
Agreements
(U.S.T.),
if
therein.
However,
if
the
treaty
is
not
20
reported
there,
cite
to
Treaties
and
Other
International
Acts
Series
(T.I.A.S.).
If
the
treaty
can
be
found
in
neither
of
those
sources,
cite
to
the
Statutes-at-Large.
When
possible,
a
parallel
cite
should
be
given
to
the
Cumulative
Bulletin
(C.B.)
and
Tax
Treaties
(CCH)
after
the
primary
source
is
given
if
a
parallel
cite
cannot
be
given
to
T.I.A.S.
or
the
Statutes-at-Large.
Example:
Income
Tax
Convention,
Aug.
24,
29180,
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.M.,
art.
II(1)(l),
Apr.
16,
1945,
60
Stat.
1377.
H.
Internet
Citations:
Bluebook
rule
18
contains
a
number
of
different
citation
formats
for
Internet
sources
of
different
types.
When
citing
to
an
official
copy
of
a
source
available
online,
follow
Bluebook
rule
18.2.1(a).
URL
information
may
be
appended
(by
using
available
at)
for
ease
of
access
by
the
reader,
but
it
is
not
required.
If
a
source
exists
online
but
does
not
exist
in
traditional
print
format,
or
if
the
print
format
cannot
be
found
or
is
obscure/
unavailable,
cite
directly
to
the
Internet
source
(per
Bluebook
rule
18.2.2).
In
citing
directly
to
the
Internet
source,
follow
rules
18.2.2(a)
(authors),
18.2.2(b)
(titles),
and
18.2.2(d)
(URLs),
but
do
not
follow
rule
18.2.2(c)
(date
and
time).
Instead,
include
the
date
of
publication
of
the
article
or
particular
webpage
in
standard
date
format
without
time
stamps.
In
the
event
that
no
date
of
publication
is
provided,
record
the
date
of
access
as
last
accessed
Month
Date,
Year.
Available
at
and
exact
time
stamps
should
not
be
included.
Examples:
Author
Name,
Title
of
Article
or
Subpage,
WEBSITE
NAME,
May
1,
2014,
http://www.mainpage.com.
[where
the
date
of
publication
is
noted
on
the
webpage
as
May
1,
2014]
Author
Name,
Title
of
Article
or
Subpage,
WEBSITE
NAME,
last
accessed
May
1,
2014,
http://www.mainpage.com.
21
[where
no
date
of
publication
is
noted
on
the
webpage,
but
the
article
was
last
accessed
on
May
1,
2014]
I.
Attribution
Footnotes
Authors
must
include
an
attribution
footnote.
Note
or
Comment
author
attribution
footnotes
should
be
placed
as
a
footnote
to
the
authors
name
at
the
end
of
the
Note
or
Comment,
and
should
include
the
authors
J.D.
information
and
any
acknowledgements.
Additional
information
can
be
included
if
desired
by
the
author.
Example:
Thomas
S.
Thomas100
100Georgetown
University
Law
Center,
J.D.
Candidate
2014.
The
author
would
like
to
thank
Catharine
Wilde,
a
Partner
at
Hogan
Polk
&
Crutcher;
Georgetown
University
Law
Center,
J.D.,
2006,
for
her
assistance
with
and
contributions
to
this
article.
Article
authors
should
include
an
attribution
footnote
to
be
placed
at
the
beginning
of
the
Article.
The
name
of
the
author
should
be
followed
by
the
authors
occupation,
educational
information,
and
any
acknowledgements.
Additional
information
about
the
contributor
may
also
be
included
if
desired
by
the
author.
Because
this
will
be
the
first
footnote,
it
should
not
be
denoted
by
a
number
but
should
instead
be
set
off
with
an
asterisk.
Example:
JOSEPH
A.
SMITH*
*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
would
like
to
thank
Articles
with
two
authors
require
two
separate
attribution
footnotes.
Example:
JOSEPH
A.
SMITH*
&
THOMAS
L.
JONES**
*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
would
like
to
thank
**Professor
of
Law,
Georgetown
University
Law
Center;
22
TEXTUAL
EDITING
23
I.
Introduction
This
Part
is
divided
into
three
subsections.
The
first
subsection
discusses
the
various
formatting
rules
that
are
applicable
to
pieces
submitted
to
The
Tax
Lawyer
for
publication.
The
second
subsection
includes
other
specific
rules
to
watch
for
when
editing
the
text.
The
final
subsection
reviews
requirements
for
abstracts
and
tables
of
contents
in
articles.
As
always,
this
manual
should
be
used
in
conjunction
with
the
Bluebook
and
the
TMOUS,
but
should
always
supersede
them
where
they
may
differ.
When
textually
editing
an
article
or
note,
always
err
on
the
side
of
conservatism.
Unless
a
specific
grammar
rule
or
rule
from
this
Citation
&
Style
Manual,
the
Bluebook,
or
TMOUS
has
been
broken,
leave
the
authors
wording
and
construction
as
you
find
it.
II.
Text
Formatting
(1)
Word
Processing
&
Fonts:
Microsoft
Word
should
be
used
to
write
pieces
for
submission
to
The
Tax
Lawyer.
The
text
should
be
in
Courier
New
12
point
font.
(2)
Paragraphs
&
Spacing:
All
articles
and
notes
should
be
double-spaced
for
submission
and
editing
and
will
be
reverted
to
single-spacing
during
typesetting.
However,
there
should
not
be
an
extra
Enter
or
blank
lines
between
paragraphs.
Instead,
the
first
line
of
the
paragraph
should
be
indented
by
a
0.5
tab.
There
should
only
be
ONE
SPACE
after
a
period.
(3)
Block
Quotations:
The
block
quotation
should
be
indented
once
on
each
side
by
0.5
inches.
Two
enter
returns
should
both
precede
and
follow
block
quotations.
The
entire
text
of
the
quotation
should
be
in
10
point
font,
and
the
quotation
should
be
justified.
Block
quotations
in
footnotes
should
be
formatted
in
the
same
manner.
(4)
Titles
&
Authors
name:
An
article
title
should
be
bolded
and
aligned
to
the
left.
There
should
be
an
Enter
between
the
Articles
main
title
and
its
subtitle,
to
be
denoted
by
a
colon.
After
the
title,
press
the
Enter
key
three
times
so
that
there
are
two
blank
lines
before
the
authors
name
is
added
in
all
capitals.
An
Attribution
footnote
(discussed
above)
should
be
indicated
using
an
asterisk.
Note
and
Comment
titles
follow
the
same
format,
except
that
NOTE
or
COMMENT
should
be
bolded
and
appear
in
its
own
line
above
the
main
title.
A
note
authors
name
is
not
included
at
the
beginning
of
the
note,
but
should
appear
at
the
end
of
the
note
after
a
single
Enter
line,
and
should
be
flush
to
the
right
margin
and
italicized.
An
attribution
footnote
(discussed
above)
should
be
indicated
using
the
next
numerical
footnote.
(5)
Headings:
There
are
four
different
levels
of
headings,
increasing
with
the
level
of
specificity.
Roman
numeral
headings
are
the
first
level.
They
should
be
flush
with
the
left
margin
and
bolded.
The
heading
should
be
formed
by
writing
the
numeral,
a
period,
and
adding
two
spaces
before
the
title
of
the
heading.
Capital
letter
headings
are
the
second
level.
They
should
also
be
flush
with
the
left
margin,
and
the
title
of
the
heading
should
be
italicized;
however,
the
capital
letter
itself
should
24
not
be
italicized.
After
the
letter
and
a
period,
there
should
be
two
spaces
before
the
heading
title
begins.
The
third
level
is
Arabic
numeral
headings.
These
should
be
indented
five
spaces
from
the
margin,
which
is
usually
equivalent
to
a
tab.
Like
the
capital
letter
headings,
the
title
of
the
heading
should
be
italicized
but
the
numeral
itself
should
not.
After
the
numeral
and
a
period,
there
are
two
spaces
before
the
title
of
the
heading
begins.
Lowercase
letter
headings
are
the
fourth
and
final
level.
These
should
also
be
indented
five
spaces
from
the
left
margin.
Like
the
capital
letter
and
Arabic
numeral
headings,
the
letter
should
not
be
italicized
whereas
the
heading
title
should
be.
After
the
letter
and
the
period,
there
should
be
two
spaces
before
the
heading
title.
The
title
of
the
heading
should
be
followed
with
a
period,
and
the
first
paragraph
of
the
subsection
should
start
two
spaces
after
the
title
instead
of
following
a
return
key
like
in
the
other
levels.
Example:
NOTE
Retroactivity
and
the
Remains
of
Chevron
Oil
After
Harper
v.
Virginia
Department
of
Taxation
I.
Background
First
paragraph
of
text...
Second
paragraph
of
text...
A.
Supreme
Court
Action
Note
text...
1.
Expenses
of
Administration
Note
text...
a.
Congressional
Treatment.
Note
text...
II.
Analysis
First
paragraph
of
text...
Last
paragraph
of
text...
Authors
Name101
25
Where
a
case
name
is
included
in
a
heading
where
the
heading
title
is
italicized,
it
should
usually
be
in
regular
typeset
in
order
to
set
it
off.
However,
where
the
case
name
stands
alone,
it
should
remain
italicized.
Example:
A
Different
Point
of
Venue:
The
Plainer
Meaning
of
Section
7482(b)(1)
AUTHORS
NAME*
I.
Background
First
paragraph
of
text...
Second
paragraph
of
text...
A.
The
Importance
of
King
v.
Commissioner
Article
text...
1.
Prior
Case
Law
Article
text...
a.
Porzio
v.
United
Tech,
Inc.
Article
text...
(6)
Self-referencing:
Within
an
article,
the
article
should
refer
to
itself
as
Article
and
not
paper,
ensuring
the
Article
is
always
capitalized.
Likewise,
any
note
should
refer
to
itself
as
Note
and
not
paper,
with
Note
(or
Comment)
always
being
capitalized.
Whenever
making
reference
to
a
part
or
subpart,
Part
should
be
capitalized.
Example:
This
Note
will
explore
the
differences
between
the
facts
and
circumstances
of
the
case
at
hand
and
the
facts
and
circumstances
present
in
the
cases
the
court
relied
on
to
make
its
distinction.
In
Part
II,
the
three
major
precedential
cases
will
be
introduced
and
analyzed.
In
this
Part,
however...
III.
Textual
Style
Rules
A.
The
Code,
the
Service,
and
the
Regulation:
In
textual
sentences,
all
references
to
the
Internal
Revenue
Code
and
the
Internal
Revenue
Service
should
be
shortened
to
references
to
the
Code
and
the
Service
as
opposed
to
the
I.R.C.
or
the
I.R.S.
Refer
to
sections
of
the
Code
as
section
1234
in
textual
sentences,
not
section
1234
of
the
Code
or
Code
section
1234.
26
Example:
The
Service
promulgated
several
new
regulations
regarding
the
reformed
Code
in
1996.
NOT
The
Internal
Revenue
Service
promulgated
several
new
regulations
regarding
the
I.R.C.
in
1996.
Likewise,
whenever
a
regulation,
temporary
regulation,
or
proposed
regulation
is
referenced
SPECIFICALLY
in
a
sentence,
Regulation,
Temporary
Regulation,
or
Proposed
Regulation
should
be
capitalized.
When
a
particular
section
is
mentioned
textually,
section
should
be
spelled
out
instead
of
using
the
symbol,
but
the
word
section
should
not
be
capitalized.
Example:
The
Proposed
Regulation
drew
nearly
1,000
comments
from
members
of
the
mining
industry.
In
particular,
Proposed
Regulation
section
1.2553-1(b),
which
sought
to
renew
tax
credits
for
natural
gas
explorations...
B.
Common
Punctuation
Errors
(1)
Hyphenation:
When
forming
compounded
nouns
or
adjectival
or
adverbial
phrases,
err
on
the
side
of
not
using
a
hyphen
and
consult
TMOUS
Rules
1.28
to
1.32
for
further
guidance.
However,
words
beginning
with
non
are
never
hyphenated;
likewise,
carryover,
carryback,
and
rollover
should
remain
unhyphenated
whenever
they
are
used
as
nouns.
Nonetheless,
if
the
latter
are
to
be
used
as
verbs,
they
should
be
separated
and
used
without
a
hyphen.
Example:
The
company
must
carry
over
its
loss
carryover
in
order
to
satisfy
the
Regulations
requirements.
(2)
Quotations:
DO
NOT
USE
CHAPTER
8
of
THE
TMOUS.
Instead,
follow
these
guidelines
as
well
as
those
provided
in
the
Bluebook.
Whenever
an
author
quotes
more
than
5
words
in
a
row
directly
from
a
source,
quotation
marks
must
be
inserted
UNLESS
the
author
is
quoting
a
statute
or
regulation,
which
do
not
require
quotation
marks.
(3)
Solidus:
A
solidus,
or
slash,
should
almost
never
be
used.
Instead,
an
en-dash
or
the
word
or
should
be
inserted.
Example:
The
Third
Circuit
rejected
a
substantivenonsubstantive
distinction
in
U.S.
income
tax
law.
27
NOT
The
Third
Circuit
rejected
a
substantive/nonsubstantive
distinction
in
U.S.
income
tax
law.
Likewise,
and/or
should
never
be
used.
Instead,
and
oror
both
construction
should
be
inserted.
Example:
The
Tax
Court
ruled
that
the
tax
could
be
considered
a
penalty
or
a
burden
to
commerce
or
both.
NOT
The
Tax
Court
ruled
that
the
tax
could
be
considered
a
penalty
and/or
a
burden
to
commerce.
(4)
Oxford
Commas:
An
oxford
comma,
the
last
comma
before
and
or
or
in
a
list,
should
always
be
included.
Example:
The
book
had
been
taken
by
Erica,
Rob,
or
Katharine.
NOT
The
book
had
been
taken
by
Erica,
Rob
or
Katharine.
(5)
Dashes:
Please
consult
TMOUS
1.27
to
ensure
that
you
are
differentiating
between
hyphens,
en-dashes,
and
em-dashes
correctly.
In
order
to
insert
the
proper
dash,
use
the
Insert
Special
Characters
tool
under
Microsoft
Word.
There
are
no
spaces
between
the
em-dash
and
the
words
it
is
connecting.
Note
that
en-dashes
are
used
for
year
or
date
ranges;
hyphens
are
used
for
page
ranges.
Example:
A
brief
must
have
at
least
three
partsthe
facts,
the
issues,
and
the
argumentto
qualify
for
the
moot
court
competition.
NOT
A
brief
must
have
at
least
three
parts
the
facts,
the
issues,
and
the
argument
to
qualify
for
the
moot
court
competition.
28
(6)
Ellipses:
Review
Bluebook
Rule
5.3
for
proper
use
of
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
matter
before
or
after
a
quotation
accordingly.
(7)
Typesetting:
Whenever
you
are
using
small
caps,
consult
the
bluebook
to
ensure
which
parts
are
intended
to
be
small
caps
and
which
must
return
to
regular
caps.
In
particular,
with
government
documents,
always
check
to
make
sure
that
you
have
not
continued
to
use
small
caps
for
ANY
numbers
that
are
contained
therein.
Example:
STAFF
OF
THE
JOINT
COMMITTEE
ON
TAXATION,
GENERAL
EXPLANATION
OF
THE
TAX
REFORM
ACT
OF
1986
(1987).
NOT
STAFF
OF
THE
JOINT
COMMITTEE
ON
TAXATION,
GENERAL
EXPLANATION
OF
THE
TAX
REFORM
ACT
OF
1986
(1987).
C.
Numbers
(1)
General:
Spell
out
any
numbers
ten
and
below
(rather
than
the
99
or
below
guideline
in
the
rulebook),
and
use
numerals
for
anything
higher.
If
a
series
includes
numbers
larger
than
ten
and
smaller
than
ten,
then
all
numbers
in
the
series
should
be
written
as
numerals.
Otherwise,
the
ten
or
below
test
is
applied
to
each
number
independently.
Numbers
used
in
the
text
including
four
or
more
digits
should
include
a
comma,
unless
the
citation
format
indicates
that
no
comma
should
be
used.
Example:
The
statutes
of
limitations
are
12,
5,
and
20
years,
respectively.
There
were
12
robberies
in
two
days,
each
punishable
by
three
months
in
jail.
(2)
Percentages:
Spell
out
the
word
percent
only
when
the
number
itself
is
spelled
out.
If
the
number
is
not
spelled
out,
use
the
percentage
symbol
without
including
a
space
between
that
symbol
and
the
number.
Example:
The
amount
of
taxes
owed
rose
20%
over
the
given
period.
(3)
Dollars:
When
reporting
currency
amounts,
always
use
the
dollar
symbol
followed
by
digits,
unless
the
symbol
would
be
the
first
word
in
the
sentence,
in
which
case
the
word
dollars
should
be
spelled
out
after
the
number
is
given.
29
Example:
The
taxpayer
was
assessed
to
owe
$362,000
in
property
taxes.
362,000
dollars
would
be
assessed
to
the
taxpayer.
If
the
dollar
amount
is
one
million
or
greater,
spell
out
the
word
million
after
providing
the
dollar
sign
and
the
million.thousands
decimal.
However,
if
the
thousands
number
is
all
zeros
(for
example,
2,000,000),
resulting
in
only
a
zero
in
the
tenths
decimal
place,
drop
both
the
decimal
point
and
the
zero.
Example:
The
trust
had
accrued
$3.45
million
in
employee
withholding.
The
corporation
paid
$1
million
in
tax
last
year.
NOT
The
corporation
paid
$1.0
million
in
tax
last
year.
(4)
Page
Numbers
&
Years:
Page
number
ranges
should
follow
standard
Bluebook
rules
for
series
and
should
only
repeat
the
last
two
digits,
unless
the
third
or
greater
to
last
digit
is
also
differentiated.
Hyphens
are
used
for
page
ranges.
However,
years
should
always
be
written
out
in
their
entirety,
even
when
describing
a
range.
En-dashes
are
used
for
date
ranges
and
to
can
be
used
for
additional
clarity.
Example:
22See
supra
note
15
at
980-99.
The
taxpayer
paid
capital
gains
rates
on
the
distributions
19801999.
The
taxpayer
paid
capital
gains
rates
on
the
distributions
from
1980
to
1999.
(5)
Setting
Off
Numbers
in
Series:
When
a
listed
series
is
included
in
the
text,
it
should
be
set
off
by
Arabic
as
opposed
to
Roman
numerals.
Example:
The
Supreme
Court
failed
to
analyze
the
three
major
prongs
of
the
taxpayers
argument:
(1)
the
legislature
did
not
intend
the
tax
to
be
applied
retroactively,
(2)
there
was
no
plain
text
directive
for
the
tax
to
be
applied
retroactively,
and
(3)
the
tax
could
not
be
applied
retroactively
on
due
process
grounds.
30
NOT
The
Supreme
Court
failed
to
analyze
the
three
major
prongs
of
the
taxpayers
argument:
(i)
the
legislature
did
not
intend
the
tax
to
be
applied
retroactively,
(ii)
there
was
no
plain
text
directive
for
the
tax
to
be
applied
retroactively,
and
(iii)
the
tax
could
not
be
applied
retroactively
on
due
process
grounds.
D.
Miscellaneous
(1)
Description
of
Litigation:
Instead
of
using
the
terms
plaintiff
or
defendant,
the
description
should
be
framed
in
the
terms
of
the
parties
involved.
In
particular,
the
taxpayer
should
always
be
described
as
the
taxpayer
as
opposed
to
the
plaintiff
or
the
petitioner.
(2)
I.e.,
e.g.:
These
terms
should
only
be
used
in
footnotes
and
in
parenthetical
matter.
They
should
always
be
italicized
and
followed
by
an
unitalicized
comma.
Note
that
I.e.,
means
that
is
and
E.g.,
means
for
example.
(3)
Equations:
Any
equations
included
in
the
text
should
be
set
off
in
italics.
(4)
Defined
Terms:
All
defined
terms
and
abbreviations
used
in
the
article
that
need
to
be
defined
should
be
defined.
See
TMOUS
Rule
1.05(b)
for
how
to
treat
defined
terms
within
the
text.
IV.
Abstracts
and
Tables
of
Contents
All
articles
submitted
to
The
Tax
Lawyer
must
also
include
an
abstract
and
an
internal
table
of
contents.
Abstracts
should
be
no
longer
than
500
words
total
and
should
not
contain
any
footnotes,
disclaimers,
URLs,
or
other
methods
of
reference
or
redirection.
Abstracts
will
only
be
edited
to
conform
to
these
style
rules
and
to
those
style
and
grammatical
rules
of
the
TMOUS.
31