§7460 — Provisions of special application to divisions
11 cases·2 overruled·9 cited
Statute Text — 26 U.S.C. §7460
A division shall hear, and make a determination upon, any proceeding instituted before the Tax Court and any motion in connection therewith, assigned to such division by the chief judge, and shall make a report of any such determination which constitutes its final disposition of the proceeding.
The report of the division shall become the report of the Tax Court within 30 days after such report by the division, unless within such period the chief judge has directed that such report shall be reviewed by the Tax Court. Any preliminary action by a division which does not form the basis for the entry of the final decision shall not be subject to review by the Tax Court except in accordance with such rules as the Tax Court may prescribe. The report of a division shall not be a part of the record in any case in which the chief judge directs that such report shall be reviewed by the Tax Court.
11 Citing Cases
7460; Succession ofMcCord v. Commissioner, 461 F.3d 614, 622 (5th Cir. 2006), rev'g 120 T.C. 358 (2003). These disputes are almost always about the law and not about factfinding. As the trialjudge in these cases, I have reviewed Judge Thornton's opinion ofthe Court and agree with his findings offacts (with one exception, see infra note 9). I s
7460; Succession ofMcCord v. Commissioner, 461 F.3d 614, 622 (5th Cir. 2006), rev'g 120 T.C. 358 (2003). These disputes are almost always about the law and not about factfinding. As the trialjudge in these cases, I have reviewed Judge Thornton's opinion ofthe Court and agree with his findings offacts (with one exception, see infra note 9). I s
ved with a copy thereof. The above time periods may be extended by the Special Trial Judge. After the time for objections and responses has passed, the Chief Judge shall assign the case to a Judge for preparation of a report in accordance with Code section 7460. 9(...continued) that case, i.e., that there is no deficiency and no addition to tax due from the Lisles for the taxable year 1984, was entered Nov. 20, 2003, and is otherwise final. See secs. 7481(a)(1), 7483. Although the Clerk of the C
ved with a copy thereof. The above time periods may be extended by the Special Trial Judge. After the time for objections and responses has passed, the Chief Judge shall assign the case to a Judge for preparation of a report in accordance with Code section 7460. 9(...continued) that case, i.e., that there is no deficiency and no addition to tax due from the Lisles for the taxable year 1984, was entered Nov. 20, 2003, and is otherwise final. See secs. 7481(a)(1), 7483. Although the Clerk of the C
ved with a copy thereof. The above time periods may be extended by the Special Trial Judge. After the time for objections and responses has passed, the Chief Judge shall assign the case to a Judge for preparation of a report in accordance with Code section 7460. 9(...continued) that case, i.e., that there is no deficiency and no addition to tax due from the Lisles for the taxable year 1984, was entered Nov. 20, 2003, and is otherwise final. See secs. 7481(a)(1), 7483. Although the Clerk of the C
ved with a copy thereof. The above time periods may be extended by the Special Trial Judge. After the time for objections and responses has passed, the Chief Judge shall assign the case to a Judge for preparation of a report in accordance with Code section 7460. 9(...continued) that case, i.e., that there is no deficiency and no addition to tax due from the Lisles for the taxable year 1984, was entered Nov. 20, 2003, and is otherwise final. See secs. 7481(a)(1), 7483. Although the Clerk of the C
ved with a copy thereof. The above time periods may be extended by the Special Trial Judge. After the time for objections and responses has passed, the Chief Judge shall assign the case to a Judge for preparation of a report in accordance with Code section 7460. 9(...continued) that case, i.e., that there is no deficiency and no addition to tax due from the Lisles for the taxable year 1984, was entered Nov. 20, 2003, and is otherwise final. See secs. 7481(a)(1), 7483. Although the Clerk of the C