Tax News

CCH (cch.taxgroup.com) reports:

A Tax Court action did not qualify for small case designation because the total amount of unpaid tax, interest and penalties exceeded the jurisdictional limit for small cases. Eligibility for such designation in Code Sec. 6015"stand-alone" innocent spouse cases is based on the aggregate unpaid tax and assessed interest for all years for which relief is sought in the petition, together with all accrued unassessed interest and penalties for such years, measured as of date of the petition. While the total amount of unpaid tax and assessed interest and penalties in the taxpayer's case was less than $50,000, when added to accrued unassessed interest and penalties, the total exceeded the jurisdictional limit for small case designation, even though each individual year's total fell below such threshold. Accordingly, the case had to be continued under regular case procedures.
G.A. Petrane, 129 TC No. 1, Dec. 57,018
Other References:
Code Sec. 6015
CCH Reference - 2007FED ¶35,192.815
Code Sec. 7463
CCH Reference - 2007FED ¶42,119.16
CCH Reference - 2007FED ¶42,119.20
Tax Research Consultant
CCH Reference - TRC LITIG: 7,006.10