26-CM2_Appendix7

26-CM2_Appendix7 - APPENDIX 7 FEDERAL TAXATION MATERIALS...

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APPENDIX 7 F EDERAL T AXATION M ATERIALS This appendix is limited to statutory, judicial, and administrative sources. Cite tax treaties and secondary sources relating to taxation—such as treatises, books, legal periodicals, and looseleaf services—using the general rules for those sources in the Manual . This appendix is divided into the following sections: A. Statutory Compilations B. Courts and Reporters 1. Trial Courts Where Federal Tax Cases Are Heard 2. Appellate Courts for Federal Tax Cases 3. Unreported Opinions C. Administrative Materials 1. Administrative Announcements 2. I.R.S. Compilations 3. Officially Published I.R.S. Pronouncements 4. Publicly Released I.R.S. Pronouncements 5. Taxpayer Forms and Publications A. Statutory Compilations Although the Internal Revenue Code is located in Title 26 of the United States Code, tax courts and practitioners typically cite the separate Internal Revenue Code (I.R.C.). When citing material within the Internal Revenue Code, include the abbreviation ‘‘I.R.C.,’’ a section symbol followed by one space, and the section number; and enclose the date in parentheses. See Sidebar A7-1 for additional information on the date. Practitioners sometimes do not include the year if citing the current version of the I.R.C.; however, a date is encouraged. If citing an unofficial version of I.R.C., such as the I.R.C. that appears within the United States Code Annotated or the United States Code Service, include the publisher’s name before the date. If citing a portion of the I.R.C. that no longer is in effect, follow Rule 14.3, except enclose in a separate parenthetical the year of the version of the I.R.C. under which the section was promulgated. For additional information on citing federal statutes, consult Rule 14. Examples Official version: I.R.C. § 165(g) (2000). Unofficial version: Repealed section: I.R.C. § 275(c) (1939) (repealed 1954). 489
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APPENDIX 7: FEDERAL TAXATION MATERIALS SIDEBAR A7-1 VERSIONS OF THE INTERNAL REVENUE CODE The current Internal Revenue Code (I.R.C.) was enacted in 1986 and applies to transactions occurring after October 22, 1986. Other versions since 1900 were the I.R.C. of 1939 (which applies to most transactions that occurred between January 1, 1939 until August 16, 1954), and the I.R.C. of 1954 (which applied to income tax transactions that occurred on or after January 1, 1954, to estate tax matters that occurred after August 16, 1954, and to gift tax transactions that occurred on or after January 1, 1955; it applied until the 1986 I.R.C. was enacted). B. Tax Courts and Reporters 1. Trial Courts Where Federal Tax Cases Are Heard United States District Courts The official reporters are the Federal Reporter (F., F.2d) through 1931 and the Federal Supplement (F. Supp., F. Supp. 2d) after 1931. Cite the official reporter when available. See
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This note was uploaded on 03/31/2012 for the course TAX 4001 taught by Professor Robertmcgee during the Spring '09 term at FIU.

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26-CM2_Appendix7 - APPENDIX 7 FEDERAL TAXATION MATERIALS...

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