Cline v. Comm'r

1 Citing case

  1. Mandy Mobley Li v. Comm'r of Internal Revenue

    22 F.4th 1014 (D.C. Cir. 2022)   Cited 259 times   2 Legal Analyses
    In Li v. Commissioner, 22 F.4th at 1017, the U.S. Court of Appeals for the District of Columbia Circuit explained that the Court has jurisdiction under section 7623(b)(4) with respect to a "determination regarding an award."

    A threshold rejection of a Form 211 by nature means the IRS is not proceeding with an action against the target taxpayer. See Cline v. Comm'r , 119 T.C.M. (CCH) 1199, 2020 WL 1249454, at *5 (T.C. 2020). Therefore, there is no award determination, negative or otherwise, and no jurisdiction for the Tax Court.