Is the Deadline to File a Tax Court Petition Jurisdictional?
Whether the deadlines to file a United States Tax Court petition are jurisdictional has been a developing issue over the last two years and has been discussed in previous issues of the EA Journal (see the Fall 2023 and Spring 2024 Tax Cou... Thomas Gorczynski, EA, USTCP
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