Wednesday, October 16, 2013

U.S. Tax Court Filings During The Shutdown

We previously posted on Saturday, October 5, 2013, Suspension of Tax Court Operations During Government Shutdown regarding the cancellation of Tax Court Trial Sessions Scheduled to Begin October 7 and 8, 2013.

What does the taxpayer with a Statutory Notice of Deficiency or Statutory Notice of Determination, which gives the taxpayer 90 days from the date of the notice file a Tax Court petition to when the Tax Court is closed?

Without a timely filed petition, the Tax Court lacks subject-matter jurisdiction over the taxpayer’s case and the taxpayer loses the Tax Court as a forum in which to litigate.  The remaining litigation forums require the taxpayer to pay the disputed tax, penalties and interest and sue for refund. 

No comments:

Post a Comment