Section 2. Answers›35.2.2 Answers›Form of Answers
Title of Answer
Internal Revenue Manual Part 35. Chief Counsel Directives Manual Tax Court Litigation · 2026-10-03 edition · updated 2026-10-04 · United States
The answer shall contain a heading or title indicating the type of answer being filed. Usually, the first answer filed in the case is titled Answer. Other headings which should be used, when appropriate, are: Answer to Petition, as Amended; Answer to Amended Petition; Amended Answer; Amendment to Answer; or Second Amended Answer; etc., or a combination of these types of answers, such as Amended Answer to Petition, as Amended.
If the petition is amended by the filing of an "amendment to the petition" prior to the filing of the original answer, the title of the document would be Answer to Petition, as Amended. The due date of this pleading is computed from the date the amendment to the petition is served. This title would be applicable unless a complete "amended petition" was filed. In such case the heading would be Answer to Amended Petition. Care must be exercised to title the document to specifically identify the particular petition, original or as amended, which is being answered. The Tax Court’s web site (www.ustaxcourt.gov) may be consulted to determine how the court has designated a particular pleading.
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