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8.4.1.2
(10-26-2007)
Defining Docketed Cases
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Appeals mission statement states Appeals will close as many docketed cases as possible to avoid going to trial.
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A docketed case is a tax case assigned a docket number in the U.S. Tax Court. These cases include petitions filed in response to:
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Notices of deficiency;
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Final adverse determination letters; and
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Final partnership administrative adjustments (FPAA).
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A regular case is a tax case with a deficiency of more than $50,000 (including deficiency amount, additions to tax, additional amounts and
penalties) for any one taxable period.
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Taxpayers may elect to have their case conducted under the Court's simplified small tax case or "S"
case procedures. Trials in small tax cases generally are less formal and result in speedier disposition. However, decisions entered
pursuant to small tax case procedures cannot be appealed. See IRC 7463 for details. Taxpayers may elect small tax case procedures
for tax disputes involving $50,000 or less (including tax and penalties.
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Rev. Proc. 87-24, 1987–1 C.B. 720, describes the procedures for handling docketed cases in Appeals and Counsel.
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Direct questions concerning Tax Court jurisdiction through the Field Counsel assigned to the case, to Branch 3 of the Office
of Administrative Provisions and Judicial Practice.
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Refer to IRM 13.1.7, Taxpayer Advocate Case Processing, for criteria to determine when it is necessary to refer a case to
Taxpayer Advocate Services (TAS), and guidelines for processing TAS cases from assignment to completion.
8.4.1.2.1
(10-26-2007)
Designation Identifying Types of Docketed Cases
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The Tax Court uses the following identification terms or letters after the docket number to designate the different types
of docketed cases:
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