US Tax Court Summary Opinions

A Summary Opinion is issued in an small procedure case. A Summary Opinion cannot be relied on as precedent, and the decision cannot be appealed.

The tax laws provide for small (S case) procedures for resolving disputes between taxpayers and the IRS. To have your case tried as an S case, you must qualify and choose to have S case procedures applied to your case and the Tax Court must agree with your choice. Generally, the Tax Court will agree with your request if you qualify for S case procedures.

  • In a deficiency case, the amount of the deficiency and any additions to tax or penalties–but not including interest–that you dispute for each year must be $50,000 or less.
  • In a collection action, the total unpaid tax (including interest and penalties) for all years cannot exceed $50,000.
  • In a request for spousal relief, the total amount of relief sought (including interest and penalties) cannot exceed $50,000.
  • In a worker classification case, the amount of employment taxes in dispute cannot exceed $50,000 for any calendar quarter.
  • In an interest abatement case, the amount of the abatement sought cannot exceed $50,000.


At the time of this writing, the US Tax Court has not issued any noteworthy summary opinions.


QuickStart Guide to Accounting for Cost of Goods Sold Copyright © 2019 by reecejr1 and Reece B. Morrel, Jr. JD MBA CPA CGMA AEP®. All Rights Reserved.

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