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Information About Filing a Case in the United (United States Tax Court)

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Information About Filing a Case in the United States Tax Court
Attached are the forms to use in filing your case in the United States Tax Court. It is very important that
you take time to carefully read the information on this page and that you properly complete and submit these
forms to the United States Tax Court, 400 Second Street, N.W., Washington, D.C. 20217, or file the forms
electronically pursuant to the Court’s eFiling provisions.
Small Tax Case or Regular Tax Case
If you seek review of an action (other than a whistleblower or a certification action) listed in paragraph 1
of the petition form (Form 2), you may file your petition as a “small tax case” if your dispute meets certain
dollar limits (described below). “Small tax cases” are handled under simpler, less formal procedures than
regular cases. However, the Tax Court’s decision in a small tax case cannot be appealed to a Court of Appeals
by the IRS or by the taxpayer(s). You can choose to have your case conducted as either a small tax case or a
regular case by checking the appropriate box in paragraph 4 of the petition form (Form 2). If you check neither
box, the Court will file your case as a regular case.
Dollar Limits: Dollar limits for a small tax case vary slightly depending on the type of IRS action you
seek to have the Tax Court review:
(1) If you seek review of a Notice of Deficiency, the amount of the deficiency (including any additions to
tax or penalties) that you dispute cannot exceed $50,000 for any year.
(2) If you seek review of a Notice of Determination Concerning Collection Action, the total amount of
unpaid tax cannot exceed $50,000 for all years combined.
(3) If you seek review of a Notice of Determination Concerning Relief From Joint and Several Liability
Under Section 6015 (or if the IRS failed to send you any Notice of Determination with respect to a request for
spousal relief that you submitted to the IRS at least 6 months ago), the amount of spousal relief sought cannot
exceed $50,000 for all years combined.
(4) If you seek review of a Notice of Determination of Worker Classification, the amount in dispute
cannot exceed $50,000 for any calendar quarter.
(5) If you seek review of a Notice of Final Determination for [Full/Partial] Disallowance of Interest
Abatement Claim (or if the IRS failed to send you a Notice of Final Determination with respect to a claim for
interest abatement that you filed with the IRS at least 180 days before), the amount of the abatement cannot
exceed $50,000.
Enclosures
To help ensure that your case is properly processed, please enclose the following items when you mail
your petition to the Tax Court:
1. A copy of any Notice of Deficiency, Notice of Determination, or Final Determination the IRS sent you;
2. Your Statement of Taxpayer Identification Number (Form 4);
3. The Request for Place of Trial (Form 5); and
4. The $60 filing fee, payable by check, money order, or other draft, to the "Clerk, United States Tax
Court"; or, if applicable, the fee waiver form.
For further important information, see the Court’s Web site at www.ustaxcourt.gov or the “Information
for Persons Representing Themselves Before the U.S. Tax Court” booklet available from the Tax Court.
UNITED STATES TAX COURT
www.ustaxcourt.gov
(FIRST) (MIDDLE) (LAST)
(PLEASE TYPE OR PRINT) Petitioner(s)
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
Docket No.
PETITION
1. Please check the appropriate box(es) to show which IRS ACTION(S) you dispute:
G Notice of Deficiency
G Notice of Determination Concerning Collection Action
G Notice of Final Determination for [Full/Partial]
Disallowance of Interest Abatement Claim (or Failure
of IRS to Make Final Determination Within 180 Days
After Claim for Abatement)*
G Notice of Determination of Worker Classification*
G Notice of Determination Concerning Relief From Joint
and Several Liability Under Section 6015 (or Failure of
IRS to Make Determination Within 6 Months After
Election or Request for Relief)*
G Notice of Certification of Your Seriously Delinquent
Federal Tax Debt to the Department of State
G Notice of Determination Under Section 7623
Concerning Whistleblower Action*
*For additional information, please see “Taxpayer Information: Starting a Case” at
www.ustaxcourt.gov (accessible by hyperlink from asterisks above, or in the Court’s information booklet).
2. If applicable, provide the date(s) the IRS issued the NOTICE(S) checked above and the city and State of the IRS office(s)
issuing the NOTICE(S):
3. Provide the year(s) or period(s) for which the NOTICE(S) was/were issued:
4. SELECT ONE OF THE FOLLOWING (unless your case is a whistleblower or a certification action):
If you want your case conducted under small tax case procedures, check here: G (CHECK
If you want your case conducted under regular tax case procedures, check here: G ONE BOX)
NOTE: A decision in a “small tax case” cannot be appealed to a Court of Appeals by the taxpayer or the IRS. If you
do not check either box, the Court will file your case as a regular tax case.
5. Explain why you disagree with the IRS determination in this case (please list each point separately):
T.C. FORM 2 (REV. 11/18)
These forms can be filled-in and printed directly from
Adobe Reader. However, please be aware that the
information you enter on a form cannot be saved to disk
unless you are using the full Adobe Acrobat software suite.
To begin, move your mouse pointer over the Petitioner(s)
name field. Your pointer will turn into a vertical beam,
indicating that you are over an editable field. Simply click
once and begin typing. Use the Tab key to move forward
through the form fields (Shift+Tab to move backwards).
6. State the facts upon which you rely (please list each point separately):
You may use additional pages to explain why you disagree with the IRS determination or to state additional facts.
Please do not submit tax forms, receipts, or other types of evidence with this petition.
ENCLOSURES:
Please check the appropriate boxes to show that you have enclosed the following items with this petition:
G A copy of any NOTICE(S) the IRS issued to you
G Statement of Taxpayer Identification Number (Form 4) (See PRIVACY NOTICE below)
G The Request for Place of Trial (Form 5) G The filing fee
PRIVACY NOTICE: Form 4 (Statement of Taxpayer Identification Number) will not be part of the Court’s public files.
All other documents filed with the Court, including this Petition and any IRS Notice that you enclose with this Petition, will
become part of the Court’s public files. To protect your privacy, you are strongly encouraged to omit or remove from this
Petition, from any enclosed IRS Notice, and from any other document (other than Form 4) your taxpayer identification
number (e.g., your Social Security number) and certain other confidential information as specified in the Tax Court’s “Notice
Regarding Privacy and Public Access to Case Files”, available at www.ustaxcourt.gov.
SIGNATURE OF PETITIONER DATE (AREA CODE) TELEPHONE NO.
MAILING ADDRESS CITY, STATE, ZIP CODE
State of legal residence (if different from the mailing address): E-mail address (if any):
SIGNATURE OF ADDITIONAL PETITIONER (e.g., SPOUSE) DATE (AREA CODE) TELEPHONE NO.
MAILING ADDRESS CITY, STATE, ZIP CODE
State of legal residence (if different from the mailing address): E-mail address (if any):
SIGNATURE OF COUNSEL, IF RETAINED BY PETITIONER(S) NAME OF COUNSEL DATE
TAX COURT BAR NO. MAILING ADDRESS, CITY, STATE, ZIP CODE
E-MAIL ADDRESS (AREA CODE) TELEPHONE NO.
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Completed 6 March 2021

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