Estate of Willis Edward Clack, Deceased, Marshall & Ilsley Trust Company, Co-Personal Representative, and Richard E. Clack, Co-Personal Representative - Page 49

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          1055, 1059 (1979), revd. and remanded on another issue 639 F.2d             
          805 (D.C. Cir. 1981).3  This venue issue arises under a specific            
          Internal Revenue Code provision applicable only to the Tax Court            
          and appears to be an issue of first impression.                             
               Section 7482(b)(1) provides with respect to review of                  
          decisions of the Tax Court:                                                 
                    SEC. 7482(b).  Venue.--                                           
                    (1) In General.--Except as otherwise provided in                  
               paragraphs (2) and (3), such decisions may be reviewed by              
               the United States court of appeals for the circuit in which            
               is located--                                                           
                         (A) in the case of a petitioner seeking                      
                    redetermination of tax liability other than a                     
                    corporation, the legal residence of the petitioner,               
                         (B) in the case of a corporation seeking                     
                    redetermination of tax liability, the principal place             
                    of business or principal office or agency of the                  
                    corporation, or, if it has no principal place of                  
                    business or principal office or agency in any judicial            
                    circuit, then the office to which was made the return             
                    of the tax in respect of which the liability arises,              
                         (C) in the case of a person seeking a declaratory            
                    decision under section 7476, the principal place of               
                    business, or principal office or agency of the                    
                    employer,                                                         
                         (D) in the case of an organization seeking a                 
                    declaratory decision under section 7428, the principal            
                    office or agency of the organization, or                          
                         (E) in the case of a petition under section 6226             
                    or 6228(a), the principal place of business of the                
                    partnership.                                                      
               If for any reason no subparagraph of the preceding sentence            
               applies, then such decisions may be reviewed by the Court of           

          3  See also Peat Oil & Gas Associates v. Commissioner, T.C. Memo.           
          1993-130, appeal dismissed without published opinion for improper           
          venue 12 F.3d 214 (6th Cir. 1993).                                          



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