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The United States Tax Court is a Federal trial court. Because it is a court of record, a record is made of all its proceedings. It is an independent judicial forum.
The Internal Revenue Service (IRS) is a unique federal agency because it is subject to the jurisdiction of different trial courts, the two most important of which are the United States Tax Court, a specialized court of limited jurisdiction, and the United States District Court, a court of general jurisdiction.
Congress created the Tax Court as an independent judicial authority for taxpayers disputing certain IRS determinations. The Tax Courts authority to resolve these disputes is called its jurisdiction. Generally, a taxpayer may file a petition in the Tax Court in response to certain IRS determinations.
The Court may, in its discretion, conduct hearings to ascertain whether a default has been committed, to determine the deci- sion to be entered or the sanctions to be imposed, or to ascer- tain the truth of any matter.
U.S. Tax Court. The U.S. Tax Court is a specialized court that hears only federal tax cases at the trial level. Before 1943, the U.S. Tax Court was called the Board of Tax Appeals (BTA).
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Taxpayers have the right to appeal an IRS decision in an independent forum. One way taxpayers may exercise this right is by filing a petition with the United States Tax Court.
What happens after I finish my trial? The Judge may direct the filing of posttrial briefs or may permit the parties to make oral argument or file memoranda or statements of legal authority. A brief is a legal document in which a party presents proposed findings of fact and legal arguments.
(a) Caption; Names of Parties: Every pleading shall contain a caption setting forth the name of the Court (United States Tax Court), the title of the case, the docket number after it becomes available (see Rule 35), and a designation to show the nature of the pleading.

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