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Section of Taxation
Manual on Government Submissions
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REQUIRED COGS REVIEWER CHECKLIST

YES

NO

  1. Is the required Executive Summary summarizing the principal points and suggestions made included at the front of the report?
  1. Is the required standardized cover sheet included on the first page of the report (form of "Status Sheet" is in the COGS Manual).
  1. Has the person responsible for preparation of the comments complied with the Statement of Policy (copy of which is set forth in the COGS Manual)?
  1. Do all references to cases, rulings, or other legal authority have an appropriate citation?
  1. If the Committee Chair has indicated that the comments may involve a definable minority position, has a statement of minority position been included?

Review Criteria

YES

NO

  1. Organization: Are the comments
  • Clearly written?
  • Well organized?
  • Internally consistent from a stylistic standpoint?
  1. Balance and Tone: Are the substantive points
  • Technically accurate?
  • Intellectually honest?
  • Not obviously unbalanced toward particular client interests?
  • Not obviously unbalanced toward results that reflect clearly bad tax policy?

Are suggestions practical and administrable?

Are issues addressed with fair, tightly reasoned arguments and not mere opinion?

Are alternative ways to address the policy objectives of the government discussed?

  1. Specific language: Do the comments avoid
  • Hyperbole and rhetoric (words such as "ridiculous" and "totally unjustified")?
  • The imperative (phrases such as "must be revised" instead of "We recommend")?
  • The prescriptive (phrases such as "should be revised" instead of "it would be helpful")?

NOTE: Should the answer to any of the foregoing questions be "no," the COGS Reviewer must advise the contact person of the particular problems raised by any negative response.

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