The US Tax Court is a federal court that decides cases involving tax related disputes. It operates as an independent judicial body within the legislative branch of the government and is a trial court of record. The U.S Tax Court was established by Congress utilizing the powers granted to it by Article I of the U.S. Constitution. Section 8 of the Article permits the Congress to “constitute Tribunals inferior to the Supreme Court.”
Certain notable points about the U.S Tax Court are:
- Its jurisdiction is limited to cases involving federal income, death, and other taxes.
- It is an Administrative Court.
- It handles disputes between tax payers and Internal Revenue Service.
- There are no jury trials.
- The time limit to file a petition is within 90 days of receiving a statutory notice from the Internal Revenue Service.
- It is the only forum to litigate without paying the tax to the department. The full payment rule is inapplicable here.[i]
The U.S. Tax Court was initially created as the U.S. Board of Tax Appeals by the Revenue Act of 1924. The Tax Reform Act of 1969 changed its name to the U.S. Tax Court.
The term of a U.S. Tax Court judge is 15 years. The U.S Tax Court’s office is situated in Washington D.C. There is also a field office on Los Angeles, California. Its sessions are conducted wherever practicable in the U.S depending on the taxpayer’s convenience.
[i] Tax disputes brought before the United States District Court, or in the United States Court of Federal Claims require that tax be paid first and a lawsuit can be filed later to recover it.