After the Service has answered the petition and you’ve replied if necessary, the next step is often an appeals conference with the IRS Office of Appeals. Appeals is in theory a separate and independent branch of the Service, but for all practical purposes, if you are...
If everyone knows what they are doing and is playing by the rules, formal discovery should not be necessary. By the time you have completed the Branerton process of informal discovery, the parties should have a pretty good idea of the fact issues about which they...
In the Branerton case, the court observed that the stipulation process is “the bedrock of Tax Court practice” and acts “as an aid to the more expeditious trial of cases.” In other decisions, Tax Court has said of the stipulation of facts that it “eliminates burdensome...
