Source and Citation Standards
What a CostSeg SI citation must include, which URLs are allowed, and when a page is marked verified, partial, or held.
Educational information, not tax advice.
Updated 2026-10-14
Key takeaways
- Cite the document that was opened, not a secondary summary of it.
- Pinpoints (page, paragraph, subsection) appear only when confirmed.
- A held page has no body and is not filled with a guessed replacement case.
Each high-risk claim — a tax rule, a date, a dollar limit, a case holding, or a classification — is supposed to have a register row with the claim in plain words, the authority, the primary URL, the date, what the source establishes, and the limits. This page restates those standards for readers of the public library.
A citation on a CostSeg SI page is a pointer to a document a reader can open. It is not decoration, and it is not a claim that a qualified reviewer has blessed the sentence. The publication record on each article still says the sources were drafted as verified or partial and that expert review has not occurred. The pages are still listed for search.
These standards exist because cost-segregation content is easy to fake. Captions get copied from marketing lists. Bonus percentages get copied from last year’s blog post. Matrix rows get treated as statutes. The rules below are the ones this library actually used when the research register was compiled on October 16, 2026.
Allowed primary hosts
Statutes: uscode.house.gov or Cornell LII. This library’s §167, §168, §179, §481, §1245, and §1250 citations were opened on LII. If LII and the slip law diverge after a later amendment, the enacted text controls. Public Law 119-21 was opened as the congress.gov slip-law PDF, not as a news summary of that PDF.
Regulations: eCFR or Cornell LII. Treas. Reg. §1.48-1 is the classification regulation this library cites most often. Treas. Reg. §1.168(k)-2 is the bonus-depreciation acquisition-date regulation that Notice 2026-11 applies with substituted dates. Treas. Reg. §1.263(a)-3 is the improvement and unit-of-property regulation. A blog’s restatement of those sections is not a citation.
IRS: irs.gov PDFs and HTML pages. Publications, notices, revenue procedures, Actions on Decision, and form instructions must be the irs.gov file that was opened, with the revision date recorded. Publication 5653 (February 2025), Publication 946 (2025), Notice 2026-11, Notice 2026-16, Rev. Proc. 2025-32, and Rev. Proc. 2025-23 are examples. A third-party HTML copy of an IRS PDF is not an allowed host for a new claim.
Cases: official court sites, CourtListener, Justia, Leagle, or another reporter page that was actually opened. A caption copied from a marketing site is not a citation. Hospital Corporation of America is cited from the Leagle opinion page and from IRS Action on Decision 1999-008. Whiteco and Scott Paper are cited from the OpenJurist pages that were opened. Peco Foods is cited from the Eleventh Circuit PDF on media.ca11.uscourts.gov. AmeriSouth is cited from the Tax Court memorandum PDF that was opened. Where a holding is taken only from Publication 5653’s case table, the page must say the opinion itself was not opened.
What a citation must contain
Name the document a reader can retrieve: the Code section, the regulation section, the publication number and revision, the notice or revenue-procedure number, or the case caption and reporter citation. Then give the URL that was opened. A “see generally IRS” sentence is not a citation.
Pinpoints — a subsection, paragraph, page, or IRB page — appear only when they were confirmed on the opened text. Inventing §168(k)(6)(A)(iii) because it looks precise is a standards violation. If the research register marks a pinpoint as unconfirmed, the public page omits it.
Dates travel with time-sensitive claims. A bonus-depreciation rate needs an as-of date. A §179 dollar limit needs the revenue-procedure year. A Form 3115 change number needs the automatic-change list that was opened, not the December 2022 instruction booklet that predates it. Publication 5653 needs its February 2025 revision date whenever it is used for examiner practice.
Limits travel with the claim. Action on Decision 1999-008 acquiesced in Hospital Corporation of America’s legal test and nonacquiesced in the item results; a citation that drops the nonacquiescence is incomplete. Publication 5653 says it cannot be cited as authority; a citation that treats a Chapter 7 row as a statute is incomplete. Notice 2026-11 is interim and requires all-or-nothing reliance on sections 3 through 5; a citation that calls it a final regulation is incomplete.
Grades
Verified — citation, court or issuer, and date confirmed on a source page. A verified grade means the writer opened the URL and found the stated point. It does not mean a CPA signed the page. It does not mean the claim is the only reasonable reading of a close factual record.
Partial — some fields confirmed; the article must say which ones. Metro National’s item list taken from an IRS written determination, or a case holding taken from Publication 5653 Table 1 without the opinion PDF, are typical partial rows. The public sentence should not sound more certain than the register row.
Unverified — must not appear as fact. Unopened captions, undated bonus percentages, and competitor savings statistics stay out of the body. If a topic still needs to be acknowledged, the page says the point was not confirmed.
Mismatch — the inventory caption is not a cost-segregation classification opinion, so the page states the decision that was opened and the limit. L.A. Darling Co. v. Commissioner, Sperry and Hutchinson Co. v. Commissioner, Clemens v. Commissioner, and Yellow Cab Co. v. Commissioner are written that way. Cite the reporter named on the page. Do not cite the URL as if the caption itself were a building-class holding.
What is never a citation
Another firm’s website, a search-engine snippet, or an AI-generated summary of a case. Tier 4 sites were used only to see which topics readers expect. They are not listed in source arrays.
A Super Intelligence agent, a proposed workflow stage, or an internal research note that was not attached to an opened URL. Internal notes can point a writer to a PDF. Only the PDF is the citation.
A matrix row used outside its industry without an analogy label. Publication 5653 Chapter 7 says each matrix reflects that industry’s general fact pattern and may not apply to other industries. Citing the restaurant carpet row for an office, without saying it is an analogy, fails these standards.
A quotation longer than a short phrase, presented as original teaching. Short quotations from statutes or opinions are allowed when marked as quotations and cited. Paraphrase is the default. Competitor sentence structure is not a source and is not reused.
Sources
- 1IRS Publication 5653 — Cost Segregation Audit Techniques Guide (rev. 2-2025)(opens in a new tab)
Written for IRS examiners. The guide states it is not an official pronouncement of law and cannot be cited as authority. It predates the July 2025 law.
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