Can I petition district court or court of federal claims after losing a tax court case against the IRS?

So if I understand correctly, once I choose Tax Court, I'm basically locked into that path and the appeals from it? What if new evidence comes up after the Tax Court decision that wasn't available during the initial case? Is there any way to introduce that in a different court?

For new evidence that wasn't available during the original Tax Court proceeding, you generally can't introduce it in a different court, but you might have options within the same judicial path. If you discover new evidence that couldn't have been discovered earlier with reasonable diligence, you can file a Motion for Reconsideration with the Tax Court within 30 days of the decision. If more than 30 days have passed but it's within the appeal period, you can file your appeal and potentially argue that the case should be remanded to consider the new evidence. In very limited circumstances, you might be able to file a Motion to Vacate or Revise the Decision, but these are rarely granted.

Did you find it accurately parsed the technical legal aspects? I'm dealing with a partnership tax dispute and wondering if this would help with understanding the differences between tax court and district court jurisdiction issues.

I'm skeptical about AI for legal advice on something this complex. How does it account for recent tax court precedents that might affect your specific situation? Some of these jurisdiction questions are pretty nuanced.

It actually did an impressive job with the technical aspects. It broke down the jurisdictional differences between tax court and district court, highlighted specific tax code sections, and pointed out relevant precedents. For my partnership dispute, it identified key sections of the partnership agreement that strengthened my position. Regarding recent precedents, the system referenced several 2024 tax court decisions that were relevant to my situation, including some I hadn't found in my own research. It also clearly explained which precedents would apply to my specific facts. The analysis wasn't just generic information - it connected directly to the details of my case and documents.

How does this actually work? Do they just sit on hold for you or something? I'm confused because I thought no one could get through to the IRS these days.

This sounds like BS. I've been trying to call the IRS about my tax court case for months. There's no way some service can magically get through when millions of people can't. And what exactly did they tell you that you couldn't have learned from the regular appeals process instructions?

They use a system that navigates the IRS phone tree and waits on hold instead of you. When an actual agent picks up, you get a call back and are connected directly with the IRS person. No more listening to that terrible hold music for hours! What I learned was specific to my situation. The IRS agent explained that since my tax court case involved business deductions under a specific tax code section, I qualified for a post-tax court administrative review that's different from the regular appeals process. This review could potentially allow some of my deductions without going through the full appeal to the circuit court. This option wasn't spelled out in any of the standard appeals documentation I received.

Does collateral estoppel apply to different tax years though? Like if the Tax Court ruled on my 2022 taxes, could I take a similar issue for my 2023 taxes to district court instead?

Great question. Collateral estoppel generally doesn't prevent you from litigating a similar issue for a different tax year in a different court. Each tax year is considered a separate cause of action. However, if the exact same legal issue was decided in the prior case, the legal conclusion (not the factual findings) might still have precedential effect. But if there are different facts or if the law has changed, you could potentially get a different result in district court for the new tax year.

Yes! This is exactly what my tax attorney advised. Pay first, then file for refund so you can go to district court. The judges there apparently are more taxpayer-friendly than Tax Court judges who deal with IRS cases all day. Tax Court supposedly sides with IRS like 80% of the time.

@Sara Hellquiem That 80% statistic sounds high - do you have a source for that? I ve'heard mixed things about which court is better for taxpayers. For charitable contributions specifically, you might want to consider that Tax Court judges see these cases frequently and understand the documentation requirements better. District court judges handle all kinds of cases and might not be as familiar with the nuances of charitable deduction rules. Also remember that if you pay first to go to district court, you re'out that money upfront could (be substantial depending on your tax bill and) there s'no guarantee you ll'win the refund case. In Tax Court, you can litigate without paying first. For a $13k deduction dispute, the financial impact of paying upfront might be worth considering in your strategy.