People
The taxpayer bringing a case before the Tax Court
Petitioner
A federal court that hears appeals by taxpayers from
adverse IRS decisions about tax deficiencies. United
States Tax Court.
Tax Court
Prepared by IRS Counsel, the document Respondent
files in response to a petition, admitting or denying
each allegation in the petition.
The Answer
pre-trial conference between Counsel and the Petitioner(s) for the purpose of making good faith efforts to exchange facts, documents, and other information.
Branerton conference
The Commissioner of Internal Revenue (CIR) in all SND cases petitioned to the US Tax
Court
Respondent
The location designated by the petitioner(s) for his/her
case to be heard by a judge. Petitioner(s) designates
when he/she submits the petition to the Tax Court.
Place of Trial
A written request filed by one or both parties for the
Court to take some action is known
Motion
contain the unagreed report, Compliance and Appeals workpapers, and tax
return.
Administrative File, Admin File
This individual licensed and admitted to practice before the Tax Court, entitled to file and receive all pleadings and other documents before the Court.
Attorney of Record or Counsel of Record
A directive issued by the court requiring action by one or both parties, the petitioner or the respondent
Order
an assessment is made based on a Statutory Notice of Deficiency (SND), assessed before the Service is aware that the taxpayer(s) has filed a Tax Court petition.
Premature Assessment
A detail of proposed adjustments, computation of revised tax liability and
deficiency or overassessment.
Audit Statement form 5278.
A spouse not a part of the Appeal despite being included on the SND
Nonpetitioning Spouse (NPS)
having jurisdiction to hear cases in one of the 13 judicial circuits of the United
States
Circuit Court (also called US Court of Appeals)
This document is often prepared by the Appeals
Officer for the signature of the Petitioner, Respondent,
and the Tax Court judge, when a case is settled.
Decision Document
refers to the name of the parties on a court record
Caption