Skip to content

of days›Note:

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.

Get a plain-English answer with a citation back to this text.

Ask AI about this code
▸Contents — Internal Revenue Manual Part 8. Appeals

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.