Internal Revenue Code Citations:
If you are citing ot the current edition of the Code, use the abbreviations "I.R.C." and provide only the section number, using regular Bluebook rules for numbering.
Example:
I.R.C. § 61.
I.R.C. §§ 55–59.
I.R.C. § 368(a), (c).
DO NOT use "Id." when referring ot 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:
1.) I.R.C. § 897(f).
2.) § 897(e).
NOT
1.) I.R.C. § 897(f).
2.) Id. 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)
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Federal and State Statutes: Follow appropriate bluebook form under Rule 12 and Table 1. Remember, you must use the hard copy of the Code ot verify the year of the Code used.
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Named Acts: For 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.
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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. (PGH) ¶ 54,332 (1939).
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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) ¶ 2004–046, 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. (PGH) ¶ 44,073, at 501 (1944).
Content taken as written from the American Bar, The Tax Lawyer, Citation and Style Manual.