Is the required Executive Summary summarizing the principal points and suggestions made
included at the front of the report?
Is the required standardized cover sheet included on the first page of the report (form
of "Status Sheet" is in the COGS Manual).
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)?
Do all references to cases, rulings, or other legal authority have an appropriate
citation?
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
Organization: Are the comments
Clearly written?
Well organized?
Internally consistent from a stylistic standpoint?
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?
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.