Also known as: TC · Tax Court · United States Tax Court · U.S. Tax Court
Written by attorneys · grounded in primary & secondary sources — see below
A specialized federal trial court that adjudicates disputes between taxpayers and the Internal Revenue Service over federal tax liabilities and deficiencies.
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Thomas Thompson received a notice of deficiency from the IRS claiming he underreported income from a real estate sale. He timely filed a petition in T.C. to contest the determination before paying the assessed amount. The court scheduled a trial to determine whether the sale qualified for capital gains treatment.
Tara Tran inherited property subject to a mortgage and later sold it at a gain. She petitioned T.C. after the Commissioner disallowed her claimed basis adjustment for the full debt amount. The court examined whether the mortgage relief constituted part of the amount realized on the disposition.
Theo Thomas stopped filing returns after attending seminars asserting the tax laws were unconstitutional. He faced criminal charges and sought to introduce his good-faith belief as a defense. T.C. proceedings were referenced to show the civil consequences that preceded the indictment.
Talia Torres paid fixed amounts to her church in exchange for auditing sessions and claimed them as charitable contributions. The IRS disallowed the deductions, and she litigated the issue in T.C. The court considered whether the payments were made with the expectation of a return benefit.
Tanner Thompson's tax shelter case was assigned to a special trial judge in T.C. for an initial report. He objected that the assignment violated Article III, prompting review of the Tax Court's internal procedures for assigning complex cases.
Tobias Thomas's estate involved a trust whose validity turned on state law. Federal estate tax liability depended on that characterization, so the executor litigated the issue in T.C. The court independently determined the property interest rather than deferring to the state trial court judgment.
A taxpayer files the petition in the United States Tax Court, commonly abbreviated T.C.
T.C. resolves federal income, estate, gift, and certain excise tax controversies between taxpayers and the Commissioner of Internal Revenue.
A T.C. decision is appealable to the appropriate circuit court of appeals and carries precedential weight within the Tax Court itself.
…Cooper v. Newell , 173 U. S. 555, 567. [^maj-5]: See also New York Life Ins. Co. v. Head , 234 U. S. 149, 161; Bonaparte v. Tax Court , 104 U. S. 592, 594. Compare Atchison, T. & S. F. Ry. v. Sowers , 213 U. S. 55, 70; Tennessee Coal, Iron & R. Co. v. George , 233 U. S. 354, 360. [^maj-6]: For decisions construing state…