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US Tax Court is an Article I court, established in 1924. Ordinarily the taxpayer (individual or corporation) is the petitioner (the plaintiff) seeking a refund, exemption or some similar break from the IRS. By not following through on a case, the taxpayer loses his chance for a decision in his favor.
On the other hand, when the IRS is trying to pry money loose from someone who refuses to pay, that is usually in a district court, an Article III court capable of imposing not only judgments and fines, but even prison sentences.
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