Chief Counsel to Follow ‘Bluebook' Citation in Tax Court

The IRS Office of Chief Counsel March 13 issued a notice (CC-2012-007) stating that The Bluebook: A Uniform System of Citation is the source for citation to be used in legal work, including U.S. Tax Court documents.

Note that case citations should be to the official reporter that is listed in T1 of the Bluebook, such as the United States Reporter or to the United States Tax Court Reports, rather than the document reprinted in a commercial service, such as Commerce Clearing House or Prentice Hall. If a case is not reported in an

official reporter, the citation should be to the slip opinion. In addition to citing to the slip opinion, a

parallel citation may be included to Westlaw or Lexis.

The Bluebook provides that short form citations to the Code, statutes, and Treasury regulations should cite to the section preceded by a section symbol. In Counsel documents, subsequent citations after the first full citation to the Internal Revenue Code and to the applicable regulations should instead be made to section numbers. For example, “section 61” may be used in citing to I.R.C. § 61 and “section 1.61–1” may be used in citing to Treas. Reg. §1.61-1.