The Readable Code and Regs: Partnerships, 2009 Edition


edited by Glenn L. Madere, J.D., LL.M.

Readable Press, 2009, 1,078 pp. (vol. 1) and 1,382 pp. (vol. 2)

 

Every neophyte in tax practice has no doubt wondered why someone couldn’t publish a plain-language gloss of the Internal Revenue Code and associated regulations. Let’s face it: Tax statutes and regulations are not a model of lucidity. They abound in arcane terms of art, circumlocutions, bureaucratese and examples that are less than exemplary. In printed volumes, the researcher must hold his or her place with a thumb while looking up a cross-reference, which in turn refers to another section and so exhausts the researcher’s supply of thumbs, not to mention patience.

 

Now someone has published a more reader-friendly reference. The Readable Code and Regs, as the name suggests, is designed to aid the relative newcomer or veteran rusty on a particular topic with more intuitive language, without sacrificing any nuance of the original. On right-side pages are “The Verbatim Code and Regs Plus,” with marginal notes summarizing the text of cross-references. On left-side pages, the same provisions appear, translated into more straightforward prose where possible, often with additional explanatory footnotes. For example, where verbatim Treas. Reg. § 1.704-1(c) treats “precontribution appreciation or diminution in value” of property, the readable version renders the phrase as “built-in gain or loss.” Only the relevant portion of the text of a cross-reference is summarized in the side notes.

 

The brainchild of editor Glenn Madere, The Readable Code and Regs has so far tackled only IRC sections 701 through 777 and associated regulations (final, temporary and proposed), dealing with partnerships. The choice reflects Madere’s own practice experience in an area that is complex yet commonly encountered by tax practitioners. The fact that it constitutes only about 4% of the entire corpus of Treasury Regulations, yet required two thick paperback volumes, is a testament to that complexity and the prolixity of IRS regulation writers (Congress, by comparison, is laconic—the Code sections take up only a thin sliver of pages). The work reflects Madere’s 28 years of practice, including a decade conceiving it as he dealt with what he says was the frustration of navigating and digesting complex regulations.

 

Although The Readable Code and Regs is available only in print, an appendix and the Readable Press’ Web site (readablepress.com) feature a guide to using public online sources of tax law and regulation. The Readable Code and Regs includes a topical index, but most researchers would still want to keep an electronic version such as that of gpo.gov (Treasury Regs at tinyurl.com/r5zabp) bookmarked for full word-search capability. The books will be updated through planned semiannual supplements, beginning this November.

 

By JofA Senior Editor Paul Bonner

 

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