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U.S. Code, Title 26, Internal Revenue Code, Appendix
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General SummaryThe U.S. Code is a consolidation and codification by subject matter of the general and permanent laws of the United States. While every effort has been made to ensure that this reproduction of the Code is accurate, those using it for legal purposes should verify their results against the printed version of the Code available through the Government Printing Office.
Rule 152. Oral Findings of Fact or Opinion
(a) General: Except in actions for declaratory judgment or for disclosure (see Titles XXI and XXII), the Judge, or the Special Trial Judge in any case in which the Special Trial Judge is authorized to make the decision of the Court pursuant to Code Section 7443A(b)(2) or (3) and (c), may, in the exercise of discretion, orally state the findings of fact or opinion if the Judge or Special Trial Judge is satisfied as to the factual conclusions to be reached in the case and that the law to be applied thereto is clear.
(b) Transcript: Oral findings of fact or opinion shall be recorded in the transcript of the trial. The pages of the transcript that contain such findings of fact or opinion (or a written summary thereof) shall be served by the Clerk upon all parties.
(c) Citation: Opinions stated orally in accordance with paragraph (a) of this Rule shall not be cited or relied upon as precedent. However, such opinions (including findings of fact) may be referred to for purposes of the application of the doctrine of res judicata, collateral estoppel, or law of the case.
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Chicago: "U.S. Congress, Office of the Law Revision Counsel", "Rule 152. Oral Findings of Fact or Opinion," U.S. Code, Title 26, Internal Revenue Code, Appendix in U.S. Code, Title 26, Internal Revenue Code, Appendix (Washington, D.C.: Government Printing Office, 2002), Original Sources, accessed March 20, 2023, http://www.originalsources.com/Document.aspx?DocID=L8S79RQAVPGM4UY.
MLA: "U.S. Congress, Office of the Law Revision Counsel". "Rule 152. Oral Findings of Fact or Opinion." U.S. Code, Title 26, Internal Revenue Code, Appendix, in U.S. Code, Title 26, Internal Revenue Code, Appendix, Washington, D.C., Government Printing Office, 2002, Original Sources. 20 Mar. 2023. http://www.originalsources.com/Document.aspx?DocID=L8S79RQAVPGM4UY.
Harvard: "U.S. Congress, Office of the Law Revision Counsel", 'Rule 152. Oral Findings of Fact or Opinion' in U.S. Code, Title 26, Internal Revenue Code, Appendix. cited in 2002, U.S. Code, Title 26, Internal Revenue Code, Appendix, Government Printing Office, Washington, D.C.. Original Sources, retrieved 20 March 2023, from http://www.originalsources.com/Document.aspx?DocID=L8S79RQAVPGM4UY.
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