1997 U.S. Code
Title 26 - INTERNAL REVENUE CODE
RULES OF PRACTICE AND PROCEDURE OF THE UNITED STATES TAXCOURT
TITLE IV - PLEADINGS
Rule 31 - General Rules of Pleading

(a) Purpose: The purpose of the pleadings is to give the parties and the Court fair notice of the matters in controversy and the basis for their respective positions.

(b) Pleading To Be Concise and Direct: Each averment of a pleading shall be simple, concise, and direct. No technical forms of pleading are required.

(c) Consistency: A party may set forth two or more statements of a claim or defense alternatively or hypothetically. When two or more statements are made in the alternative and one of them would be sufficient if made independently, the pleading is not made insufficient by the insufficiency of one or more of the alternative statements. A party may state as many separate claims or defenses as the party has regardless of consistency or the grounds on which based. All statements shall be made subject to the signature requirements of Rules 23(a)(3) and 33.

(d) Construction of Pleadings: All pleadings shall be so construed as to do substantial justice.