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Tax Court Lacks Jurisdiction Where IRS Didn’t Send Notice

May 26, 2020, 10:56 PM

The Tax Court ruled that it didn’t have jurisdiction over a computational adjustment to a trust’s 2012 tax return because the IRS didn’t issue a notice of determination regarding actions to collect on the adjustment.

The court nonetheless denied the IRS’s request for a win without further proceedings when it came to carryforward deductions for 2014 and 2015 that were tied to the 2012 adjustment, reasoning that genuine disputes of material fact still needed to be resolved.

The case involved the Amanda Iris Gluck Irrevocable Trust, which held an indirect interest in a partnership that sold property for...

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