RULE 280. GENERAL
- (a) Applicability: The Rules of this Title XXVII set forth the
provisions which apply to actions for review of the Commissioner's
failure to abate interest under Code section 6404. Except as
otherwise provided in this Title, the other Rules of Practice and
Procedure of the Court, to the extent pertinent, are applicable to
such actions for review.
- (b) Jurisdiction: The Court shall have jurisdiction of an
action for review of the Commissioner's failure to abate interest
under this Title when the following conditions are satisfied:
- (1) The Commissioner has mailed a notice of final determination
not to abate interest under Code section 6404.
- 1(2) A petition for review of the Commissioner's failure to
abate interest is filed with the Court within the period specified
in Code section 6404(h) by a taxpayer who meets the requirements of
Code Section 7430(c)(4)(A)(ii).
1The amendment is effective as of June 30, 2003.
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