Tax Court Holds It Has Jurisdiction Over Prior Year Denial Erroneously Included In IRS Determination

Tax Court Holds It Has Jurisdiction Over Prior Year Denial Erroneously Included In IRS Determination

A recent Tax Court case considered its jurisdiction when the IRS erroneously included a denied innocent-spouse relief claim for a prior year in a later determination for another year. As the case holds, that later determination can effectively revive the Tax Court’s jurisdiction over the denied claim for the prior year because of its inclusion in the new determination—even if its inclusion was in…

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