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).
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 of Tax Case Law
Below are links to select online sources offering a range of case law involving federal taxation:
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)