U.S. Tax Court Petitions: Filing, Service, and the Administrative Record
A Tax Court petition invokes a specialized federal court's jurisdiction and must follow the statute, current court rules, and accepted filing procedures.
Read the analysisKentucky + Federal Tax Law Resource Center
Plain-English explanations of Kentucky tax statutes, the Internal Revenue Code, Treasury regulations, IRS guidance, notices, deadlines, collections, examinations, and tax-resolution procedure—edited through the lens of a Kentucky tax lawyer.
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Kentucky statutes governing assessments, protests, collections, refunds, responsible-person liability, and local occupational taxes.
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A Tax Court petition invokes a specialized federal court's jurisdiction and must follow the statute, current court rules, and accepted filing procedures.
Read the analysisAn offer package combines a legal ground for compromise, contractual terms, financial disclosure, payment rules, and collection-statute consequences.
Read the analysisPenalty relief depends on the particular penalty, governing statute, documented cause, compliance history, and applicable administrative procedure.
Read the analysisIRS collection financial statements organize assets, income, expenses, transfers, and business information used to evaluate payment and hardship options.
Read the analysisA written protest should define each disputed adjustment, state the relevant facts, apply authority, and preserve the administrative record.
Read the analysisIRS letters can create different administrative and judicial routes. The notice number and governing statute matter more than the envelope's urgency.
Read the analysisRecent U.S. Tax Court decisions
167 T.C. No. 10 (2026)
No. Section 6235(a) establishes alternative limitations periods and permits an adjustment through the latest applicable date. The consent validly extended the § 6235(a)(1) period to May 30, 2025; thus, the March 25, 2025 FPA was timely. The Court…
Read the case noteT.C. Memo. 2026-81, Docket No. 13093-25
An ITIN is not the valid identification number required by § 6428B for the 2021 recovery rebate credit; petitioner’s allowable basic credit amount was therefore zero. The Court lacked jurisdiction over petitioner’s separate 2020 claim because the notice…
Read the case noteT.C. Memo. 2026-82, docket No. 16089-25 (U.S. Tax Ct. Sept. 3, 2026)
The Court denied the Commissioner’s motion to dismiss. The Commissioner did not establish that the final determination notice was mailed by certified or registered mail as required by § 6015(e)(1)(A)(i)(I); because Wales filed more than six months after…
Read the case noteHow the library works
A statute is the starting point, not always the answer. Regulations implement it. Agency guidance explains administration. Notices create factual and procedural questions. Every guide separates those layers and links back to primary material.
Statutes, regulations, and reported authority establish the legal framework.
IRS and Kentucky guidance show how the rule is being administered.
The notice, deadline, account history, and collection posture determine what matters now.

Edited by a Kentucky tax lawyer
Darby Smith has practiced law in Kentucky since 1997 and earned his LL.M. in Taxation from New York University. He is admitted to practice before the United States Tax Court. His tax practice focuses on federal, Kentucky, other-state, and local tax controversies, collections, examinations, missing-return matters, and related resolution work.
Sarah Abraham, MST, works with Darby as the firm’s Tax Resolution Specialist, helping organize account records, delinquent-return work, financial information, and case administration.
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