The ATA Journal of Legal Tax Research publishes creative and innovative studies employing legal research methodologies that logically and clearly:

  • identify, describe, and illuminate important current tax issues including the history, development, and congressional intent of specific provisions;

  • propose improvements in tax systems and unique solutions to problems;

  • critically analyze proposed or recent tax rule changes from both technical and policy perspectives.

The ATA Journal of Legal Tax Research solicits unpublished manuscripts not currently under consideration by another journal or publisher. Each article will be published electronically as soon as the editor, based upon advice from referees, determines that the manuscript meets the objectives and standards set forth by the ATA and the Journal's editorial board.

Each manuscript submitted to The ATA Journal of Legal Tax Research is subject to the following review procedures:

  • The manuscript is screened by the editor for general suitability.

  • If the manuscript passes the initial editorial screening, it will be blind-reviewed by at least two reviewers.

  • In light of the reviewers' recommendations, a decision will be made by the editor as to whether the article will be accepted as is, revised, or rejected. It is anticipated that the decision will be communicated to the author within four to six weeks after submission.

The process described above is a general one. The editor may, in some circumstances, vary this process at his or her discretion. Through its constructive and responsive editorial procedures, the Journal aims to render research efforts relevant and rewarding for all concerned.

Manuscripts are expected to be original research that has not been previously published and not currently under review by another journal. If measurement instruments (questionnaires, case, interview plan, etc.) have been developed by the authors and are an integral part of the study, copies should be included with the manuscript. Manuscripts are to be submitted using the Manuscript Submission and Peer Review System, at The site contains detailed instructions regarding the preparation of files for submission. To ensure anonymous review, the title page is submitted as a separate file from the manuscript text. The nonrefundable submission fee in U.S. funds of $50 payable by credit card (VISA, MasterCard, or American Express only) online at If you are unable to pay by credit card or have any questions please contact the AAA Member Services Team at (941) 921-7747 or Revisions must be submitted within 12 months from notification; otherwise the manuscript will be considered a new submission.


An abstract of 100–200 words should be presented on a separate page immediately preceding the text. The abstract should concisely inform the reader of the manuscript's topic, its method, and its findings. The abstract is to be followed by four key words that will help in indexing the paper.


Citations and Other Footnotes

Authorities should be cited in footnotes using The Bluebook: A Uniform System of Citation (cited above) styles. Textual footnotes should be used for extensions and useful excursions of information that if included in the body of the text might disrupt its continuity. Footnotes should be consecutively numbered throughout the manuscript with superscript Arabic numerals.

Sample Entries for Legislative Sources

An Internal Revenue Code Section: I.R.C. §61.

An enacted bill: H.R. 3838, 99th Cong., 2d Sess. (1986) (enacted).

Congressional committee report: H.R. Rep. No. 1043, 99th Cong., 2d Sess.ll (1985), 1985-1 C.B. 412.

Congressional hearing: Senate Hearings before the Committee on Finance on Tax Reform Proposal – 1, 99th Cong., 1st Sess. 3 (1985) (Statement of Sen. Chafee).

Sample Entries for Administrative Sources

Treas. Reg. §1.162–4(a).

Rev. Rul. 83–137,1983-2 C.B. 41.

Rev. Proc. 85–37,1985-2 C.B. 66.

T.D. 7522,1978-1 C.B. 59.

Priv. Ltr. Rul. 91-10-003 (March 15,1991).

Tech. Adv. Mem. 85-04-005 (September 18,1985).

I.R.S. Notice 89-29,1989-1 C.B. 33.

Sample Entries for Judicial Sources

United State Supreme Court opinion: United States v. Mitchell, 403 U.S. 190 (1971).

Regular Tax Court opinion: Pope v. Commissioner, 114 T.C. 789 (2000).

Memorandum Tax Court opinion: Brown v. Commissioner, 65 T.C.M. (CCH) 666 (1983), T.C.M. (RIA) ¶ 93.039.

Circuit Court of Appeals opinion: White v. Commissioner, 32 F.3d 108 (CA-6 2000).

United States District Court opinion: Grey v. United States, 222 F.Supp. 109 (M.D. Georgia, 1955).

Court of Federal Claims opinion: Green v. United States, 405 F.2d 890 (Fed.Cl. 1993).

Sample Entries for Secondary Sources

Cunningham, L. E. 1964. National Health Insurance and the Medical Deduction. 50 Tax L. Rev. 237,244–6.

De Waegenaere, A., R. Sansing, and J. Wielhouwer. 2001. Valuation of Deferred Tax Assets from a Net Operating Loss Carryover. Discussion Paper No. 2001–24. Available at: (last accessed July 11,2011).

Harper, M. R. 1998. The marvel of medical savings accounts. Wall Street Journal (January 23): A-14.

Slemrod, J., and J. Bakija. 2001. Second edition. Taxing Ourselves: A Citizen's Guide to the Great Debate over Tax Reform 201. Cambridge, MA: MIT Press.

Environmental Protection Agency. Brownfields Tax Incentive Guidelines. Available at:

Horwood, R. M. 2000. Corporate Reorganizations, 52-3rd Tax Mgmt. Portfolio (BNA), at A-25.