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The United States Tax Court (in case citations, T.C.) is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 of which provides (in part) that the Congress has the power to constitute Tribunals inferior to the supreme Court.
In order to be heard by a Federal District Court or a U.S. Court of Federal Claims, a taxpayer must first pay the disputed tax and then sue for a refund. In contrast, a taxpayer can be heard in U.S. Tax Court without paying the amount in dispute prior to litigating.
All tax cases are first tried in one of three lower level trial courts: the U.S. Tax Court, U.S. District Court, or U.S. Court of Federal Claims. Tax cases tried in all of these courts are later appealed to the U.S. Courts of Appeals.
The Tax Court is the only judicial forum where you dont have to pay the proposed deficiency prior to filing a petition. If you miss the deadline in your Statutory Notice of Deficiency, the IRS will assess the taxes and any penalties proposed in the SNOD and you will have to pay the liability in full.
Generally, a taxpayer may file a petition in the Tax Court in response to certain IRS determinations. A taxpayer who begins such a proceeding is known as the petitioner, and the Commissioner of Internal Revenue is the respondent.
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Today the mission of the United States Tax Court is to provide a national forum to expeditiously resolve disputes between taxpayers and the Internal Revenue Service while carefully considering the merits of each case and ensuring the uniform interpretation of the Internal Revenue Code.
Generally, the taxpayer will have the burden of proof, because the taxpayer has easier access to documents and information substantiating the items on his or her tax return.
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. It is not controlled by or connected with the Internal Revenue Service (IRS).

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