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Prelitigation Administrative Procedures
Choice of Forum
THE UNITED STATES TAX COURT
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9th Cir AFTR2d amended amount answer appeal applicable assessment attorney burden of proof calendar Certificate of Service claim for refund Claims Court collateral estoppel Comm'r copy corporation Date and sign decision declaratory judgment action deficiency notice denied Deponent deposition determination discovery district court Docket documents evidence facts Federal filed Form FPAA fraud include a Certificate income tax return Internal Revenue Code Internal Revenue Service Interrogatories issue jurisdiction litigation mailed ment Notice of Deficiency overpayment paragraph partnership party payment penalty period petition Petitioner Petitioner's Plaintiff pleadings procedures pursuant to Rule pursuant to TCR refund claim refund suit reply Request for Admissions respect Respondent Respondent's settlement sign pursuant small tax special trial judge statement statute statute of limitations stipulation submitted Subpoena summary judgment Supp supra note Susan N Tax Court Rules tax liability tax-refund suit taxable taxpayer TC Memo tion U.S. Supreme Court UNITED STATES TAX