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What is the difference between 14 CFR 61.39(a)(6)(i) which states, "Has received and logged training time within 2 calendar months preceding the month of the application in preparation for the practical test", and 61.65(d)(2)(i) which states, "Three hours of instrument flight training from an authorized instructor in an airplane that is appropriate to the instrument-airplane rating within 2 calendar months before the date of the practical test"?
 
Namely, what is the difference between the language "preceding the month of" and "before the date of"? Is there any difference? (If not, why not use the same language?) It seems like 2 calendar months before the date of, say, March 15 could mean January 15. That would have a different meaning than 2 calendar months before March itself, which could mean anytime in January.
 
This is using a possible specific definition from Webster's for Calendar Months:
 

Definition of calendar month
1: one of the months as named in the calendar
2: the period from a day of one month to the corresponding day of the next month if such exists or if not to the last day of the next month (as from January 3 to February 3 or from January 31 to February 29)"

 
I realize I'm probably over thinking this, and guessing they mean the same thing, but it would be nice to know for sure. Asking because there have been reports at my school of a student that failed their oral exam because they didn't know the correct definition of "calendar month", and how it applies.
 
Apologies about any faux pas in this post, it's my first time!
 
References:
https://www.law.cornell.edu/cfr/text/14/61.39
https://www.law.cornell.edu/cfr/text/14/61.65
https://www.merriam-webster.com/dictionary/calendar%20month

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The way I read these two statements.

61.39(a)(6)(i) - Has received and logged training time within 2 calendar months preceding the month of application in preparation for the practical test;

This statement means that you can take the practical test on April 30th but must have received training after February 1st. This could be 88 days between the last training flight and the practical test.

61.65(d)(2)(i) - Three hours of instrument flight training from an authorized instructor in an airplane that is appropriate to the instrument-airplane rating within 2 calendar months before the date of the practical test; and

This statement means you can take the practical the practical test on April 30th but must have received training after February 28th. This could be 61 days between the last training flight and the practical test.

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    $\begingroup$ I think you're right, but man is that confusing. They could have just said "60 days" and achieved the same objective without the confusion. $\endgroup$
    – John K
    Commented Apr 2, 2022 at 17:10
  • $\begingroup$ Yes! While it seems likely they should have the same meaning, it's also very easy to read them as being different! $\endgroup$
    – Abelnewt
    Commented Apr 2, 2022 at 17:34
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    $\begingroup$ Not saying I disagree with your answer, but if he took 3 hours of training on Feb 2nd (Feb being the first "calendar month") and March being the 2nd "calendar month" then did the test on April 25th, would that work? (2 calendar months, Feb and March, before the date of the test which is on April 25th). That"s about 83 days. – $\endgroup$
    – user22445
    Commented Apr 2, 2022 at 19:03
  • $\begingroup$ @757toga. 61.39 is the requirement for any practical test and 61.65 is more restrictive for an instrument rating. $\endgroup$
    – wbeard52
    Commented Apr 2, 2022 at 19:48
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    $\begingroup$ good discussion of this question and analysis on reddit's /r/flying. $\endgroup$
    – 300D7309EF17
    Commented Apr 3, 2022 at 4:56

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