26 U.S. Code § 7479 - Declaratory judgments relating to eligibility of estate with respect to installment payments under section 6166
The court shall not issue a declaratory judgment or decree under this section in any proceeding unless it determines that the petitioner has exhausted all available administrative remedies within the Internal Revenue Service. A petitioner shall be deemed to have exhausted its administrative remedies with respect to a failure of the Secretary to make a determination at the expiration of 180 days after the date on which the request for such determination was made if the petitioner has taken, in a timely manner, all reasonable steps to secure such determination.
The 2-year period in section 6532(a)(1) for filing suit for refund after disallowance of a claim shall be suspended during the 90-day period after the mailing of the notice referred to in subsection (b)(3) and, if a pleading has been filed with the Tax Court under this section, until the decision of the Tax Court has become final.
1998—Subsec. (a)(1), (2). Pub. L. 105–206, § 6007(d), substituted “an estate (or with respect to any property included therein),” for “an estate,”.
Subsec. (c). Pub. L. 105–206, § 3104(b), added subsec. (c).
Amendment by section 3104(b) of Pub. L. 105–206 applicable to any claim for refund filed after July 22, 1998, see section 3104(c) of Pub. L. 105–206, set out as a note under section 7422 of this title.
Amendment by section 6007(d) of Pub. L. 105–206 effective, except as otherwise provided, as if included in the provisions of the Taxpayer Relief Act of 1997, Pub. L. 105–34, to which such amendment relates, see section 6024 of Pub. L. 105–206, set out as a note under section 1 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.
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- Extension of Time to Pay Estate Tax : 2009-04-10
- Declaratory Judgments Relating to Eligibility of Estate with Respect to Installment Payments Under Section 6166 : 2009-04-10
- Extension of Time to Pay Estate Tax : 2006-07-07
- Exhaustion of Administrative Remedies : 2006-07-07
- Declaratory Judgments Relating to Eligibility of Estate with Respect to Installment Payments Under Section 6166 : 2006-07-07
- Jurisdiction of Tax Court : 2006-07-07