26 U.S. Code § 7463 - Disputes involving $50,000 or less
A decision entered in any case in which the proceedings are conducted under this section shall not be reviewed in any other court and shall not be treated as a precedent for any other case.
In any case in which the proceedings are conducted under this section, notwithstanding the provisions of sections 6214(a) and 6512(b), no decision shall be entered redetermining the amount of a deficiency, or determining an overpayment, except with respect to amounts placed in dispute within the limits described in subsection (a) and with respect to amounts conceded by the parties.
At any time before a decision entered in a case in which the proceedings are conducted under this section becomes final, the taxpayer or the Secretary may request that further proceedings under this section in such case be discontinued. The Tax Court, or the division thereof hearing such case, may, if it finds that (1) there are reasonable grounds for believing that the amount of the deficiency placed in dispute, or the amount of an overpayment, exceeds the applicable jurisdictional amount described in subsection (a), and (2) the amount of such excess is large enough to justify granting such request, discontinue further proceedings in such case under this section. Upon any such discontinuance, proceedings in such case shall be conducted in the same manner as cases to which the provisions of sections 6214(a) and 6512(b) apply.
For purposes of this section, the amount of any deficiency placed in dispute includes additions to the tax, additional amounts, and penalties imposed by chapter 68, to the extent that the procedures described in subchapter B of chapter 63 apply.
A prior section 7463 was renumbered section 7465 of this title.
2000—Subsec. (f). Pub. L. 106–554 added subsec. (f).
1998—Pub. L. 105–206 in section catchline and in subsec. (a)(1) to (4) substituted “$50,000” for “$10,000”.
1990—Subsec. (f). Pub. L. 101–508 struck out subsec. (f) “Qualified State individual income taxes” which read as follows: “For purposes of this section, a deficiency placed in dispute or claimed overpayment with regard to a qualified State individual income tax to which subchapter E of chapter 64 applies, for a taxable year, shall be treated as a portion of a deficiency placed in dispute or claimed overpayment of the income tax for that taxable year.”
1984—Pub. L. 98–369, § 461(a)(2)(A), substituted “$10,000” for “$5,000” in section catchline.
Subsec. (a). Pub. L. 98–369, § 461(a)(1), substituted “$10,000” for “$5,000” in pars. (1) to (4).
1982—Section (a)(4). Pub. L. 97–362 added par. (4).
1980—Subsec. (g). Pub. L. 96–222 struck out subsec. (g) which authorized the chief judge of the Tax Court to assign proceedings conducted under this section to be heard by the Commissioners of the court.
1978—Pub. L. 95–600, § 502(a)(2)(A), substituted “$5,000” for “$1,500” in section catchline.
Subsec. (a). Pub. L. 95–600, § 502(a)(1), “$5,000 for any one taxable year, in the case of the taxes imposed by subtitle A” for “$1,500 for any one taxable year, in the case of the taxes imposed by subtitle A and chapter 12, or” in par. (1), “$5,000, in the case of the tax imposed by chapter 11, or” for “$1,500 in the case of the tax imposed by chapter 11,” in par. (2), and added par. (3).
Subsec. (g). Pub. L. 95–600, § 502(b), added subsec. (g).
1976—Subsec, (d). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.
1972—Pub. L. 92–512, § 203(b)(2), substituted “$1,500” for “$1,000” in section catchline.
Subsec. (a)(1), (2). Pub. L. 92–512, § 203(b)(2), substituted “$1,500” for “$1,000”.
Subsec. (f). Pub. L. 92–512, § 203(b)(1), added subsec. (f).
Pub. L. 92–512, title II, § 204, Oct. 20, 1972, 86 Stat. 945, as amended by Pub. L. 94–455, title XXI, § 2116(a), Oct. 4, 1976, 90 Stat. 1910; Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that:
For provisions that nothing in amendment by Pub. L. 101–508 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to Nov. 5, 1990, for purposes of determining liability for tax for periods ending after Nov. 5, 1990, see section 11821(b) of Pub. L. 101–508, set out as a note under section 45K of this title.
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.
Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.
We truncate results at 20000 items. After that, you're on your own.
- Disputes Involving $10,000 or Less : 2002-07-12