THE

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 Today

Tax Notes International (Tax
Analysts)

Tax Notes (Tax Analysts)

Tax Notes International
Weekly News (Tax Analysts)

TaxDay

Taxes on Parade (CCH)

Tulane Tax Institute

Defense Credits, 46 N.Y.U. ANN. INST. FED. TAXN

23.09, at 23-10 (1990).

Eugene Whetzel, Ohio: State Tax Commissioner
Clarifies Resident Income Tax Credit, 2 ST. TAX NOTES
(TA) 36 (Sept. 9, 1991).
Nebraska Reduces Fourth Quarter Fuel Tax Rate, ST.
TAX REV. (CCH), Sept. 3, 1991, at 1.
Foreign Currency Translation, Statement of
Financial Accounting Standards No. 52, 32 (Fin.
Accounting Standards Bd. 1982).
Reimbursements Under New Meal and Lodging Per
Diems, TAX FOCUS (CCH), Feb. 6, 1990, at 1.
The Lexis version of Tax Notes Today does not have
page numbers. Thus:

Closing Agreement on Final Determination Covering
Specific Matters, 2000 TAX NOTES TODAY 75-12 (Apr.
7, 2000).

John T. Jones, New Zealand Insurance Firms 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 Letter:
Another Round, 26 TAX NOTES (TA) 1147, 1154 (Mar.
18, 1985).
Accountant Examines U.K.'s New Simpler' Self-
Employment Rules, 2 TAX NOTES INT'L WKLY. NEWS
(TA) 23 (Aug. 24, 1991).
2000 TAXDAY, Item J.9 (Nov. 2, 2000).
Alternative Measures to Replace "Comfort Ruling"
Policy, TAXES ON PARADE (CCH), Oct. 9, 1990, at 1.
This periodical is not consecutively paginated.
Thus, references to pages should be made by
author:

Christine A. Smith, Reorganizations and
Recapitalizations, 41st Ann. Tulane Tax Inst., Smith
at 13, (1990).

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