LibGuides: Federal Tax Research: Tax Court: Memorandum Decisions

Tax Court Memorandum Decisions Basics

"Generally, a Memorandum Opinion is issued in a regular case that does not involve a novel legal issue. A Memorandum Opinion addresses cases where the law is settled or factually driven. A Memorandum Opinion can be cited as legal authority, and the decision can be appealed. . . . Generally, a Tax Court Opinion is issued in a regular case when the Tax Court believes it involves a sufficiently important legal issue or principle. A Tax Court Opinion can be cited as legal authority, and the decision can be appealed." (Tax Court Website)

Tax Case Law Reporters in Print at NYU Law Library

Memorandum decisions, while not not published officially, are available in the some commercially published sets, such as Tax Court Memorandum Decisions published by CCH and Tax Court Memorandum Decisions published by RIA (previously Prentice-Hall). They are also available online (see box to the right).

Board of Tax Appeals Memorandum Decisions (B.T.A.M. or B.T.A. Mem. Dec. (P-H.)), NYU Law Library
1928-1942. Unofficial reporter, Prentice Hall.
Tax Court Memorandum Decisions (T.C.M. (CCH)), NYU Law Library
1942-. Unofficial reporter, CCH.
Tax Court Reported & Memorandum Decisions (T.C.M. (RIA)), NYU Law School Library
1986-2006. Unofficial reporter, RIA. Each volume has a table of cases.
TC Memorandum Decisions (T.C.M. (RIA)), NYU Law Library
1942-2006. Formerly printed by Prentice-Hall, now RIA.
U.S. Tax Cases (U.S.T.C.), NYU Law Library
1913-2011. Unofficial reporter, CCH.

Abbreviations, Tax Case Law

Below are pertinent abbreviations.

Board of Tax Appeals Memorandum Decisions=B.T.A.M. or B.T.A. Mem. Dec.

Tax Court Memorandum Decisions=T.C.M. (CCH), (P-H) or (RIA)

Tax Court Reported Decisions=Tax Ct. Rep. Dec. (RIA]

Online Collections Offering Memorandum Decisions

Below are links to select online sources offering a range of case law involving federal taxation:

Tax Court Memoranda (Current), VitalLaw
Tax Court Memoranda (Archive), Vital Law
Tax Court Opinions, Bloomberg Law
Bloomberg Law offers citation to the CCH reporter for some memorandum decisions (T.C.M. (CCH)) but even for those there is NOT star pagination that matches pagination in that print reporter.
Court Documents, Tax Notes
Tax Notes offers citation to CCH reporter for memorandum decisions (T.C.M. (CCH)) but NOT star pagination that matches pagination in that print reporter.
Tax Court Memorandum Decisions, Checkpoint
Under the "Table of Contents" tab, navigate: Federal Library→Federal Source Materials→Federal Tax Decisions→Tax Court Memorandum Decisions
** RIA does not provide citations to the decisions in the RIA or CCH reporters.**
U.S. Tax Court Memorandum Opinions (T.C. Memo), Westlaw
Does not provide citation to the case in the RIA or CCH reporter.
TC and Memorandum Opinions, Summary Opinions, U.S. Tax Court Website
1995- (Memorandum decisions). Provides slip opinion.

Citation, Memorandum Decisions

The following citation resources may be informative. Please also see the page on citation to tax decisions in general.

Bluebook R.10, Cases
Bluebook R. 19, Services
Bluebook T1.1. Federal Judicial and Legislative Materials ("Tax Court (T.C.) (created 1942), previously Board of Tax Appeals (B.T.A.): Cite to T.C. or B.T.A., if therein; otherwise, cite to T.C.M. (CCH), T.C.M. (P-H), T.C.M. (RIA), or B.T.A.M. (P-H). . . .> Tax Court Memorandum Decisions 1942-date [T.C.M. (CCH)], 1942-1991 [T.C.M. (P-H)], 1991-date [T.C.M. (RIA)]

The Tax Court website provides:

A Memorandum Opinion is cited as [Name of Petitioner] v. Commissioner, T.C. Memo. [year issued - #]. . . . A Tax Court Opinion is cited as [Name of Petitioner] v. Commissioner, [Volume of Tax Court Reports] T.C. [page of the volume] (year issued)." (Tax Court Website)