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The United States Tax Court is established as a court of record under
Article I of the Constitution by section 7441 of the Internal Revenue Code.
The Tax Court’s jurisdiction is generally prescribed by section 7442,
but specific grants of jurisdiction are interspersed throughout the Code.
The procedure under which the court operates is prescribed in sections 7451
through 7465. Pursuant to its statutory authority in section 7453, the court
has promulgated Rules of Practice and Procedure under which it operates. Except
in proceedings conducted under sections 7436(c) and 7463, the rules of evidence
applicable in the Tax Court are the rules of evidence applicable in trials
without a jury in the United States District Court for the District of Columbia.
Section 7453. The specific Internal Revenue Code provisions conferring Tax
Court jurisdiction are discussed in subsequent text.

The Tax Court has jurisdiction to redetermine whether deficiencies determined
by the Commissioner are correct. The provisions of sections 6211 through 6216
relate to deficiency proceedings.

Other jurisdictional grants by Congress to the Tax Court are listed
below (and described at CCDM 35.1.1.3 through CCDM 35.1.1.16):

See CCDM 35.1.1.18 for other proceedings in the Tax Court involving
various declaratory judgments and worker classification cases under section
7436 where Congress has given specific grants of jurisdiction to the Tax Court.

Section 6015(e) grants the Tax Court jurisdiction to determine relief
from joint and several liability under section 6015. The Tax Court has jurisdiction
to determine relief from joint and several liability under section 6015
when a petitioner raises a claim for relief under this section in several
contexts, e.g., a deficiency proceeding under section 6213(a), a stand-alone
proceeding under section 6015(e), or a collection due process proceeding
under section 6330. The court reviews the Service’s determinations
under section 6015(b) and (c) de novo but reviews the Service’s
determinations under section 6015(f) for abuse of discretion. Section
6015(e)(1)(A) is effective with respect to any liability for tax arising after
July 22, 1998, and any liability for tax arising on or before such date but
remaining unpaid as of that date. See T.C. Rules 320–325.

Section 6226, effective for partnership years beginning after September
3, 1982, grants the Tax Court jurisdiction to determine all partnership items
for the partnership for the partnership year to which a notice of final partnership
administrative adjustments relates, the proper allocation of such items among
the partners, and the applicability of any penalty, addition to tax, or additional
amount that relates to an adjustment to a partnership item. A decision under
section 6226 has the same force and effect as a regular Tax Court decision
and is reviewable as such. See T.C. Rules 240–251.

Section 6228, effective for partnership years beginning after September
3, 1982, grants the Tax Court jurisdiction to determine those partnership
items to which the part of the tax matters partner’s request under section 6227
not allowed by the Commissioner relates and those items with respect to which
the Commissioner asserts adjustments as offsets. A decision under section 6228
has the same force and effect as a regular Tax Court decision and is reviewable
as such. See T.C. Rules 240–251.

Section 6247, effective for partnership years ending on or after December
31, 1997, grants the Tax Court jurisdiction to determine all partnership items
for the large partnership for the partnership year to which a notice of final
partnership administrative adjustments relates, the proper allocation of such
items among the partners, and the applicability of any penalty, addition to
tax, or additional amount for which the partnership may be liable under section 6242(b).
A decision under section 6247 has the same force and effect as a regular
Tax Court decision and is reviewable as such. See T.C.
Rules 300–305.

Section 6252, effective for partnership years ending on or after
December 31, 1997, grants the Tax Court jurisdiction to determine those large
partnership items to which the part of the tax matters partner’s request
under section 6251 not allowed by the Commissioner relates and those
items with respect to which the Commissioner asserts adjustments as offsets.
A decision under section 6252 has the same force and effect as a regular
Tax Court decision and is reviewable as such. See T.C.
Rules 300–305.

Section  7481(c), effective for assessments of deficiencies redetermined
by the Tax Court and made after November 10, 1988, grants the Tax Court jurisdiction
to resolve disputes that arise over the Commissioner’s post-decision
computation of interest. The Tax Court may redetermine interest in either
of the following situations: (1) an assessment has been made by the Secretary
under section 6215, which includes interest, and the taxpayer has paid
the entire amount of the deficiency plus interest claimed by the Secretary;
or (2) the Tax Court finds under section 6512(b) that the taxpayer has
made an overpayment. If the court determines either that the taxpayer has
made an overpayment of interest or that the Secretary has made an underpayment
of interest, the court will enter an order determining an overpayment of tax
pursuant to section 6512(b)(1). A decision with respect to overpayment
of interest is reviewable on appeal in the same manner as a decision of the
Tax Court with respect to the deficiency. See T.C. Rule
261.

Section 6404(i), effective for requests for abatement made after
July 30, 1996, grants the Tax Court jurisdiction to determine whether the
Commissioner’s failure to abate interest under section 6404 was
an abuse of discretion. A Tax Court decision under section 6404 is reviewable
on appeal in the same manner as a regular decision of the Tax Court but only
as to the matters determined in such decision. See T.C.
Rules 280–284.

Section 7430(f)(2), effective with respect to proceedings commenced
after November 10, 1988, establishes jurisdiction in the Tax Court to decide
appeals of taxpayers from decisions by the Internal Revenue Service denying
awards for reasonable administrative costs within the meaning of section 7430(c)(2). See T.C. Rules 270–274 and CCDM 35.10.1.2.

Section 6512(b)(2) grants jurisdiction for the Tax Court to order the
Commissioner to refund the amount of an overpayment redetermined by the Tax
Court but not paid within 120 days after the Tax Court decision is final,
together with statutory interest thereon. Pursuant to section 6512(b)(2),
as amended by the Taxpayer Relief Act of 1997, effective July 30, 1997, an
order of the Tax Court disposing of a motion to enforce the overpayment determination
is reviewable in the same manner as a decision of the Tax Court but only with
respect to the matters determined in such order. See T.C.
Rule 260.

Section 7481(d), effective with respect to Tax Court cases for
which a decision was not final on November 11, 1988, establishes jurisdiction
in the Tax Court to reopen a case in order to modify a final decision affected
by the extension of time for payment of an estate tax deficiency under section 6166. See T.C. Rule 262 and CCDM 35.9.1.3.2.3.

Section 7429(b)(2)(B), effective for assessments or levies made on or
after July 1, 1989, establishes jurisdiction in the Tax Court to review in
the same manner as a United States District Court the reasonableness of the
jeopardy assessment or levy made for deficiencies that are presently and properly
before the Tax Court for redetermination. Any Tax Court determination under
section 7429(b)(2)(B) is final and conclusive and is not reviewable in any
other court. See T.C. Rule 56.

Section 6863(b)(3)(C), effective February 8, 1989, for review of the
Commissioner’s determination to sell certain seized property, establishes
jurisdiction in the Tax Court to order a stay or approval or disapproval,
pending resolution of the underlying tax deficiency, of the sale by the Service
of the seized property. Any order of the court disposing of a motion filed
under section 6863(b)(3)(C) is reviewable on appeal in the same manner
as a decision of the Tax Court with respect to the deficiency.
See T.C. Rule 57.

Section 6330, effective with respect to collection actions commenced
after January 19, 1999, grants the Tax Court jurisdiction to review the lien
or levy determination made by the Office of Appeals under sections 6320 or
6330. See T.C. Rules 330–334.

Section 6110(f)(3) establishes jurisdiction in the Tax Court to review
determinations by the Commissioner with respect to whether, and to what extent,
written determinations and background file documents may be disclosed to the
public. See T.C. Rules 220–229A.

Ancillary to the primary jurisdiction for redetermining deficiencies,
section 6243(a) of the Technical and Miscellaneous Revenue Act of 1988 (TAMRA)
amended section 6213(a), effective November 11, 1988, to grant the Tax Court
authority to enjoin a premature assessment or collection of the deficiency,
which is the subject matter of a notice of deficiency timely petitioned to
the Tax Court. The Tax Court has promulgated T.C. Rule 55, effective July
1, 1990, to implement its jurisdiction to restrain assessment or collection.
Any order by the Tax Court resolving such an injunction proceeding is treated
as, and may be appealed, as a final decision of the Tax Court, pursuant to
section 7482(a)(3), effective November 11, 1988.