Number of current President appointed tax judges and number of official spots designated to be appointed by the President
What is seventeen and nineteen?
100
3 events that could cause an overpayment of taxes
What is over-withholding, miscalculation on tax return, and audit determination
100
strict rules of evidence are followed during this time
What is the procedure when the jury is present?
100
The only way to go to bankruptcy court
What is already filed bankruptcy?
100
claim preclusion
What is res judicata?
200
Amount at issue limit to obtain small case procedure
What is $50,000?
200
Taxpayer's statute of limitations to file a petition after receiving a denial
What is two years?
200
3 times IRS has the burden of proof
What is civil fraud, proving new matters, and when the burden shifts due to statute (ยง7491(a))?
200
location of Court of Federal Claims
What is Washington DC?
200
issue preclusion
What is collateral estoppel?
300
letter used for informal discovery that is required by a case to exhaust all informal procedures
What is Branerton letter?
300
Advantage of district court for filing a petition
What is jury trial?
300
4 costs included in reasonable litigation costs
What is court costs; reasonable expert witness fees; reasonable costs of studies, tests, and engineering reports; and reasonable attorney fees (subject to statutory cap)?
300
Court that focuses heavily on the stipulation process
What is tax court?
300
doctrine that applies when a taxpayer petitions the tax court for two years and loses in year 1, and therefore cannot challenge the issue in year 2
What is res judicata?
400
5 types of opinions
What are division opinions, memorandum opinions, summary opinions, reviewed opinions, and bench opinions?
400
Taxpayer's statute of limitations to file a petition after receiving a deemed denial and has not waived notice
What is no statute of limitations in this scenario?
400
the 3 requirements to obtain litigation costs
What is substantially prevail, administrative exhaustion, and meet income guidelines?
400
Procedure to get into the Court of Federal Claims
What is the tax payer must pay deficiency and sue for refund of assessed tax in the Court of Federal Claims?
400
case that held that the tax court takes full jurisdiction of a claim filed in both district court and tax court, if there has not been a trial in district court
What is Statland v. US
500
Recommended precedent for tax courts is the circuit which it appeals to is the holding of this case
What is Golsen v. Commissioner
500
Precedent in the Court of Federal Claims
What is Federal Circuit precedent?
500
representative of the IRS in District Court (specific)
What is tax division or U.S. Attorney's office of the Department of Justice?
500
4 choices of forum
What is bankruptcy court, tax court, Federal district court, and the Court of Federal Claims
500
the doctrine that applies when we assume TP petitions the Tax Court in year 1 and loses then sues for a refund in district court or the court of federal claims for a subsequent year in which the TP has not filed a Tax court petition
What is neither collateral estoppel nor res judicata because the taxpayer may sue for a refund in district court or the fed. Claims in a subsequent year under this scenario?