I’ll start with the bad news. The U.S. Tax Court is not a fair venue to litigate the limited application or proper enforcement of the income tax laws. The court vigorously suppresses any suggestion that there are limits to IRS authority or that the IRS might be...
TAX COURT JURISDICTION is defined by statute. There are a number of areas over which the court has jurisdiction. Chief among them are: deficiencies, overpayments,[1] interest abatement,[2] wrongfully collected amounts,[3] innocent spouse relief,[4] and worker...
THE OFFICIAL RULES of the court are titled The Tax Court Rules of Practice and Procedure. They are based on the Federal Rules of Civil Procedure, differing from them in small but important ways. Anyone conducting a case before the Tax Court is well advised to become...
Your ticket to tax court is either a statutory “Notice of Deficiency” following an audit, or a “Notice of Determination” following a Collections Due Process (CDP) hearing. Receipt of either of these notices allows you to petition the court for a decision. The...
The procedures and requirements for writing a tax court petition are in Rule 34b of the Tax Court Rules. The rules for filing a petition in a lien or levy action are found in Title XXXII of the Rules. You can download the rules from the Tax Court website or order them...
