In a textual sentence (in the text of the main body or in a footnote), the Internal Revenue
Code of 1986 should be referred to as "the Code." In a textual reference to a section of the Code,
"section" is not capitalized and is not preceded by the word "Code." Example:
The qualification requirements of section 127 are more detailed, explicit, and perhaps
stricter than those of section 117(d). Income exempt from taxation under a treaty
should also be exempt under the Code. Sections 1 and 11 provide tax rate schedules.
In section 514(c) and (d), the participating loan restrictions are relaxed for sales of
real property. Sections 53 to 59 govern the application of the Alternative Minimum
Be consistent throughout comments by using “section” in textual sentences and “§” in
The first reference to a Code section should be just to the section,
, “section 162
Then, footnote the first reference as follows:
“References to a “section” are to a section of the Internal Revenue Code of
1986, as amended (the “Code”), unless otherwise indicated.”
Internal Revenue Service.
In a textural sentence, it is preferable to refer to the Internal
Revenue Service as “the Service,”
Most importantly, be consistent with
use of “Service”
“I.R.S.” throughout the submission.
Carryover, Carryback, Rollover.
Never hyphenate these words. Separate them when used as
verbs; combine them when used as nouns.
If you are going to use a defined term, provide an explanation,
“controlled foreign corporation” within the meaning of
These signals are not interchangeable; “
,” means “that is,” and “
,” means “for
example.” Both “
,” and “
,” are always italicized and followed by a comma, which is not
italicized. The use of these terms should be restricted to footnotes and parenthetical matter.
Quotation marks must be used when taking words directly from a source. Statutes
and regulations can be quoted directly without quotation marks.
If a quotation contains at least fifty worlds or exceeds four lines of typed text present the quotation
as a block of type that is a font size smaller, single spaced and indented by one tab on both the
right and the left.
Do not use quotation marks at the beginning or end of the block quotation.
Separate the block quote from the text below and above with a blank line.
Place the note
reference number at the end of the block quotation.
As the Staff of the Joint Committee on Taxation has observed:
The present-law system thus creates a sort of paradox of defects: on the one hand, the
system allows tax results so favorable to taxpayers in many instances as to call into question
whether it adequately serves the purposes of promoting capital export neutrality or raising