Rule 61 Briefs and Memorandums
Rule Text
A Briefs. Briefs must be typewritten, double-spaced, and in a manner that, if printed, would be on 8 ½" X 11" paper. Each brief of more than five pages or which includes more than five citations must contain, in order, the following:
A(1) Title page showing the title of this court, the case number and title, the title of the brief (e.g., plaintiff’s opening brief, defendant’s answering brief, plaintiff’s reply brief), and the names of counsel;
A(2) A table of contents with page references;
A(3) An alphabetically arranged list of all citations with page reference as to page or pages of the brief on which each citation is cited. The briefs must set forth a concise statement of the case, the nature of the controversy, the type of tax involved, and the basic issue or issues to be decided. Each party must set forth its points and authorities and argument relating to each issue. Case citations must include reference to the particular page or pages of the report where the proposition of law is discussed. Federal cases should be cited by reference to official reports and unofficial reports. (If available, United States Tax Cases (CCH) and the federal court which decided the case should be indicated parenthetically by appropriate abbreviations.) Cases from other jurisdictions should be cited by reference to both official and unofficial reports where available. The argument on each issue must follow the points and authorities on that issue and must speak solely to that issue.
B Briefs and Memorandums. Trial memoranda, if any, must be filed with the tax court clerk, and copies must be delivered concurrently to the court and to opposing parties no later than noon the day before the trial takes place.⁵ All other memorandums and briefs may be filed only as authorized by statute, these rules, a schedule agreed upon in a case management conference, or by leave of the court. In any proceeding involving property taxation, each party will address its reliance, if any, on a department rule promulgated under ORS 308.205. See TCR 16 D.