APPEALED
Internal Revenue Manual Part 8. Appeals · 2026-10-03 edition · updated 2026-10-04 · United States
DEFINITION: This report lists all appealed Tax Court (bond or no bond filed) cases sent to the Court of Appeals for a final decision. The following types of cases can be appealed by the petitioner during the 90-day appeal period following the decision entered date:
case tried by the Tax Court,
decisions entered without a waiver paragraph.
OBJECTIVE: To monitor all appealed Tax Court (bond or no bond filed) cases sent to the Court of Appeals for a final decision.
FREQUENCY: The APPEALED report will be generated and worked on a monthly basis in ACTION TODATE order.
APPEALED Follow-up Number of Days: 180
PROCEDURES:
Review the entire list for incomplete case information (i.e., Counsel Office, Attorney). Write in additions/corrections/changes, etc., onto the list and then update CASES.
Determine your "cut-off" date. For reports that are due monthly, use a cut-off date equal to the current date/report run date. Draw a line under the last case with a date in the follow-up column equal to your cut-off date.
Cases listed above the line are to be researched on eCITE to ensure that the Court of Appeals has not entered a final decision.
Any contradictions on eCITE versus ACDS must be explained fully.
If you have a closure on eCITE, but have not received the administrative file, contact Counsel to obtain the file. Annotate action taken on the report.
Follow-up with Counsel is required on cases that appear on the list for more than one year, and then yearly thereafter, to confirm the status of the case.
IMPACT: The APPEALED report works in conjunction with the statute report.
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