No, not a reprise of the Céline Dion show I saw at Caesar’s years ago; this is the latest go-round of new and improved US Tax Court Rules of Practice and Procedure.
Some of the interim changes, effective without prior comment because of the need to conform to the 2015 Congressional cliffhanger, involve petitions for abatement of interest, and the obliteration of TEFRA.
It’s brand-new day for partnerships, with “partnership representatives” replacing tax matterers and notice partners, per the Bipartisan Budget Act of 2015, more properly entitled the Revenue Act of 2015, replacing the notion of an Internal Revenue Code that doesn’t change every year with Congressional cliffhanging and posturing. But this is a non-political blog, isn’t it?
Go check it out, practitioners, and delete the old boilerplate petitions from your hard drives. Here’s a link to the New Day.
http://www.ustaxcourt.gov/press/032816.pdf
So start drafting. And best of luck to you.
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