What Happens When a Tax Court Petition Is a Few Minutes Late?
The United States Tax Court is a court of limited jurisdiction; it cannot consider every tax dispute in the United States. Historically, for the Tax Court to have jurisdiction over a specific matter, the Internal Revenue Code (IRC) must allow the Tax Court to review the Inte... Thomas Gorczynski, EA, USTCP
When Is a Return Considered Filed?
In Seaview Trading, LLC v. Commissioner,i a three-judge panel of the Ninth Circuit Court heard an appeal from the Tax Court, which tasked the court with deciding when a return ... Josh Youngblood, EA
If the IRS Timely Responded, Your Offer Is Not Deemed Accepted
Brown v. Commissioner, 158 T.C. No. 9 (2022) Brown has shined light onto a provision in the Internal Revenue Code (IRC) that asserts that an offer is deemed accepted 24 months after submission if not explicitly rejected.Ruben D. Valdes, EA, USTCP