Daily Tax Report ®

Case: Certiorari Denied Where IRS Letter Fails to Confer Tax Court Jurisdiction as Notice of Determination (S. Ct.) (IRC §6330)

Feb. 22, 2021, 5:00 AM

Certiorari denied in Ninth Circuit Court of Appeals holding that the U.S. Tax Court lacked jurisdiction over a petition because the IRS Notice LT16 forming the basis of the petition was not a notice of determination, the Supreme Court ruled. Taxpayer attached to his petition an IRS Letter LT16 advising him that he was not entitled to claim exempt status and the letter does not confer jurisdiction on the Tax Court, the appeals court held. [Ryskamp v. Commissioner, No. 20-961 (S. Ct. Feb. 22, 2021)]

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