General Opinion Matters

Jasper L. Cummings, Jr., “The Reliability of Tax Writings,” 177 Tax Notes Federal 1119 (Nov. 21, 2022): The author describes the ranking of tax writings based on his believe of the reliability of such writings. Ranked in order of reliability: (1) published guidance (T.D., Rev. Rul., Rev. Proc., Notices, Announcements, AoD – i.e., everything that is published in the IRB); (2) Code; (3) properly written will and should opinions; (4) court opinions; (5) commentary; (6) litigation briefs including amicus letters. Available online at https://www.taxnotes.com/tax-notes-today-federal/tax-policy/reliability-tax-writings/2022/12/08/7fcf6.

National Association of Bond Lawyers, “Model Bond Opinion Report,” February 14, 2003: As of December 2022, this is the most recent NABL model bond opinion report. Available online at https://www.nabl.org/portals/0/documents/NABLCommentsFedTax-ModelBondOpinionReport.pdf.