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Proposed Tax Regulations Basics
"Generally, regulations are first published in proposed form in a Notice of Proposed Rulemaking (NPRM)." (IRS website) Proposed regulations are published in the Federal Register and in the Internal Revenue Bulletin.
"Proposed regulations provide guidance concerning Treasury’s interpretation of a Code section. The public is given an opportunity to comment on a proposed regulation and a public hearing may be held if a sufficient number of requests to speak at a hearing are received. . ." (Classes of Regulations, IRM § 126.96.36.199.3.3)
As per the Bluebook citation quoted below, citations to IRS tax regulations often do not include a reference to the pertinent CFR title (title 26). The CFR title number is replaced with "Treas. Reg." or "Prop. Treas. Reg."
Citation, Proposed Tax Regulations
The following citation resources may be informative.
- Bluebook T 1.2, Federal Administrative & Executive Materials ( "Although Department of Treasury regulations are published under title 26 of the C.F.R., cite as <Treas. Reg.>. . . .Cite proposed Treasury regulations to the Federal Register. > Prop. Treas. Reg. § 1.704-1, 48 Fed. Reg. 9871, 9872 (Mar. 9, 1983).")
- Bluebook R. 14, Administrative and Executive Materials
- IRM § 188.8.131.52.3.6, Citing the Regulations ("The first division is the CFR part number and indicates the subject of the regulation. The part number appears before the decimal point in a citation . . .The numbers immediately after the decimal point refer to the Code section to which the regulations apply . . .The section number of the regulation is separated from the Code section by a hyphen . . .")
- TaxCite, Pt. 1, C.1, Treasury Regulations
Abbreviations, Proposed Regulations
Below are pertinent abbreviations.
- Code of Federal Regulations=C.F.R.
- Federal Register=Fed.Reg.
- Treasury Decision=T.D. or TD
- Treasury Regulation=Treas.Reg.
Sources of Proposed Tax Regulations
Warning: Researchers should independently verify the currency of any proposed rule.
Sources of Proposed Regulations
Below are links either to sources offering proposed regulatory material--specifically sources offering the Federal Register, where proposed regulations are published. These sources are not focused on tax regulatory material. Warning: Researchers should independently verify the currency of any proposed rule.