26 U.S.C. § 7442
Jurisdiction
The Tax Court and its divisions shall have such jurisdiction as is conferred on them by this title, by chapters 1, 2, 3, and 4 of the Internal Revenue Code of 1939, by title II and title III of the Revenue Act of 1926 (44 Stat. 10–87), or by laws enacted subsequent to
Notes of Decisions
Cited in 61
cases (4 in the last 5 years), 1958–2025 · leading case: Spiridon Spireas v. Comm'r of Internal Reven, 886 F.3d 315 (3rd Cir. 2018).
Spiridon Spireas v. Comm'r of Internal Reven, 886 F.3d 315 (3rd Cir. 2018). “In the Tax Court Spireas argued the “fundamental” view that it 8 The Tax Court had jurisdiction over Spireas’s petition under 26 U.S.C. §§ 7442 and 6214. We have jurisdiction under 26 U.”
Johnny Weimerskirch v. Comm'r of Internal Revenue, 596 F.2d 358 (9th Cir. 1979). “26 U.S.C. § 7442 , et seq. After the Tax Court upheld the deficiency determination, Weimerskirch appealed to this court.”
Diversified Grp. Inc. v. United States, 841 F.3d 975 (Fed. Cir. 2016). “The Tax Court, however, is a court of limited jurisdiction, see 26 U.S.C. § 7442 , and Congress has generally declined to authorize jurisdiction over assessed penalties, such as the § 6707 penalties at issue here.”
Est. of Bessie I. Mueller, Deceased John S. Mueller, Pers. Rep. v. Comm'r of Internal Revenue, 153 F.3d 302 (6th Cir. 1998). “” 26 U.S.C. § 7442 . In addition, the Supreme Court has held that “[t]he Tax Court is a court of limited jurisdiction and lacks general equitable powers.”
Est. of Frank Branson, Deceased Mary M. March v. Comm'r of Internal Revenue, 264 F.3d 904 (9th Cir. 2001). “26 U.S.C. § 7442 . The Tax Court’s jurisdiction is defined and limited by Title 26 and it may not use general equitable powers to expand its jurisdictional grant beyond this limited Congressional authorization.”
Sally Conforte v. Comm'r of Internal Revenue, Joseph Conforte v. Comm'r of Internal Revenue, 692 F.2d 587 (9th Cir. 1982). “Sally Conforte has presented no authority for the proposition that the tax court, a court of limited jurisdiction, see 26 U.S.C. § 7442 , can review, even collaterally, the validity of an order of a United States district court.”
Conrad Gorospe Shirley Gorospe v. Comm'r of Internal Revenue, 451 F.3d 966 (9th Cir. 2006). “Its subject matter jurisdiction is statutorily granted by 26 U.S.C. § 7442 , and is defined and limited by Title 26 of the United States Code.”
Chisolm v. United States, 82 Fed. Cl. 185 (Fed. Cl. 2008). “His situation would be no different if he had mistakenly filed his complaint with the United States Tax Court, only to have it dismissed on statute of limitations grounds rather than as falling outside that court’s jurisdiction under 26 U.S.C. § 7442 . Had the district court…”
Nancy Rubel v. Comm'r Internal Revenue, 856 F.3d 301 (3rd Cir. 2017). “26 U.S.C. § 7442 . Thus, we turn to Title 26 to determine whether the Tax Court had jurisdiction to entertain Rubel’s petition to review the IRS’s denial of her request for innocent spouse relief under § 6015.”
Sanok v. Grimes, 662 P.2d 693 (Or. 1983). “” 26 USC § 7442 (1976). “Any person aggrieved by any assessment by the District of any.”
Alphonso Bax & Alice Corrine Bax, Deceased, & Alphonso L. Bax, Adm'r v. Comm'r of Internal Revenue, 13 F.3d 54 (2d Cir. 1993). “In addition, the tax court held that the Taxpayers failed to state a claim for relief under section 7481(c) and that the tax court had no authority to rule on issues involving abatement of interest pursuant to section 6404(e).”
Paolo Lo Duca v. United States, 93 F.3d 1100 (2d Cir. 1996). “This fact strongly undercuts the interpretation proffered by Lo Duca since it would be odd, to say the least, for Congress, in assigning a single task, to vest unappealable Article III power in state judges and commissioners, who lack lifetime tenure and undiminishable salaiy,…”
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