Generally, no. This "court" has very limited jurisdiction and does not administer trials by jury. Judgments are rendered by what amounts to a bunch of geriatric IRS hacks.
However, there are exceptions to every rule and the Tax Court did right in the Meyer Case - if that fails to take you there directly pull up "William B Meyer" in "Opinions Search" - in which an appeal for a Collection Due Process Hearing was upheld. There is also the Curtis case, see below.
Accordingly, the Tax Court can be extremely valuable when one's rights to due-process have been clearly denied, especially the Collection Due Process Hearing required under 26 USC 6330.
The Basic Tool Set is needed for a proper understanding of this as of all questions indexed here.
Audiotape Series 3 Tapes 1 and 3 explain why Tax Court has no authority to assess a deficiency: the Code Sections apparently giving it that power (eg 6214) have no legislative, implementing regulations - which the case of US v Mersky determined to be prerequisite.
Audiotape Series 5 Tape 3 records a victory by Laura Ann Curtis, who successfully appealed an adverse Tax Court decision.
Audiotape Series 6 shows in Tape 2 how to use the Tax Court to vacate (nullify) an alleged deficiency following a properly-run Collection Due Process Hearing ("CDPH" - see Question 50 and Question 52) for which the Meyer case set a fine precedent. Exhibits and Tapes 3 and 4 revisit and amplify.
The Tax Court Tool Kit was produced in 2001 to equip students fully to prepare for an effective encounter with Tax Court to appeal an adverse CDPH determination. Don't leave for Court without it!
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