TAX COURT JURISDICTION

IN GENERAL (RULE 13) INCOME TAX DEFICIENCY EXCISE TAX DEFICIENCY ADDITIONS TO TAX TRANSFEREE LIABILITY

DECLARATORY JUDGMENTS (TAX COURT RULES 210-218) DISCLOSURE ACTIONS (TAX COURT RULES 220-229A)

CLAIMS FOR LITIGATION AND ADMINISTRATIVE COSTS (RULES 230-233) TEFRA PARTNERSHIP ACTIONS (RULES 240-251)

PARTNERSHIP ACTIONS UNDER BBA SECTION 1101 (RULES 255.1-255.7) REDETERMINATION OF S CORPORATION ITEMS

COLLATERAL JURISDICTION Amounts Collected When IRS is Prohibited from Collection Overpayments (Rule 260)

Redetermine Interest (Rule 261) Modify Decision on §6166 Estate Election (Rule 262) ACTIONS FOR ADMINISTRATIVE COSTS (RULE 270-274)

Recovery of What Costs Award of Costs Requirements When to Request an Award of Costs Qualified Offers MEMORY TOOL – NAP PJ + LIST + PRAYER

IRS REFUSAL TO ABATE INTEREST (RULE 280-284) REDETERMINATION OF EMPLOYMENT STATUS (RULE 290-294)

LARGE PARTNERSHIP ACTIONS (RULES 300-305) DECLARATORY JUDGMENT … OVERSHELTERED RETURN (RULES 310-316)

DETERMINATION … JOINT/SEVERAL LIABILITY (RULES 320-325) Innocent Spouse (§6015(b)) Election of Separate Liability (§6015(c))

Equitable Relief (§6015(f)) Requirements Illustrated Joint return Spouse Did Not Know About the Understatement

Not Married, Widowed, Legally Separated From or Lived Apart Stand Alone Proceeding Intervenor When Can the Petition be Filed?

What Standard Applies? Equitable Relief Factors Deficiency Community Property Participate Meaningfully LIEN AND LEVY ACTIONS (RULE 330-334)

CDP QUICK & DIRTY EQUITABLE RECOUPMENT WHISTLEBLOWER ACTIONS (RULES 340-345)

CERTIFICATION/FAILURE TO REVERSE … WITH RESPECT TO PASSPORTS (RULE 350-354) NO TAX COURT JURISDICTION EXISTS

EXCLUSIVITY OF JURISDICTION PETITION PROBLEMS

JOINDER OF ISSUE (RULE 38)

JOINDER OF ISSUE (RULE 38)

ADMISSIONS (RULE 90)

ADMISSIONS (RULE 90)

STIPULATIONS (RULE 91)

STIPULATIONS (RULE 91)

PRETRIAL CONFERENCE (RULE 110)

PRETRIAL CONFERENCE (RULE 110)

SUBMISSION WITHOUT TRIAL (RULE 122)

SUBMISSION WITHOUT TRIAL (RULE 122)

DEFAULT AND DISMISSAL (RULE 123)

DEFAULT AND DISMISSAL (RULE 123)

ALTERNATE DISPUTE RESOLUTION (RULE 124)

ALTERNATE DISPUTE RESOLUTION (RULE 124)