ACC 377 Lecture Notes - Lecture 1: Certiorari, United States Court Of Appeals For The Federal Circuit, Internal Revenue Bulletin
Disagreement by the IRS on the result reached in certain judicial decisions. Nonacq. or NA.
Acquiescence
Agreement by the IRS on the results reached in certain judicial decisions; sometimes abbreviated Acq. or
A.
Writ of Certiorari
Appeal from a U.S. Court of Appeals to the U.S. Supreme Court is by Writ of Certiorari. The Supreme
Court need not accept the appeal, and it usually does not (cert. den.) unless a conflict exists among the
lower courts that must be resolved or a constitutional issue is involved.
Precedents
CA previously decided court decision that is recognized as authority for the disposition of future
decisions.
Circuit Court of Appeals
Any of 13 Federal courts that consider tax matters appealed from the U.S. Tax Court, a U.S. District
Court, or the U.S. Court of Federal Claims. Appeal from a U.S. Court of Appeals is to the U.S. Supreme
Court by Certiorari.
Small Cases Division
A division within the U.S. Tax Court where jurisdiction is limited to claims of $50,000 or less. There is no
appeal from this court.
US Tax Court
One of four trial courts of original jurisdiction that decides litigation involving Federal income, death, or
gift taxes. It is the only trial court where the taxpayer must not first pay the deficiency assessed by the
IRS. The Tax Court will not have jurisdiction over a case unless a statutory notice of deficiency (90-day
letter) has been issued by the IRS and the taxpayer files the petition for hearing within the time
prescribed.
US Court of Federal Claims
A trial court (court of original jurisdiction) that decides litigation involving Federal tax matters. Appeal
from this court is to the Court of Appeals for the Federal Circuit.
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Document Summary
Disagreement by the irs on the result reached in certain judicial decisions. Agreement by the irs on the results reached in certain judicial decisions; sometimes abbreviated acq. or. Appeal from a u. s. court of appeals to the u. s. supreme court is by writ of certiorari. Court need not accept the appeal, and it usually does not (cert. den. ) unless a conflict exists among the lower courts that must be resolved or a constitutional issue is involved. Ca previously decided court decision that is recognized as authority for the disposition of future decisions. Any of 13 federal courts that consider tax matters appealed from the u. s. tax court, a u. s. district. Court, or the u. s. court of federal claims. Appeal from a u. s. court of appeals is to the u. s. supreme. A division within the u. s. tax court where jurisdiction is limited to claims of ,000 or less.
