Michael T. Hawkins and Janine M. Hansen - Page 4

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          Tax Court may prescribe”.  Accordingly, this Court has “over many           
          years developed a comprehensive set of Rules which are designed             
          and calculated to increase our efficiency in adjudicating genuine           
          tax disputes.”  Blum v. Commissioner, 86 T.C. 1128, 1131 (1986).1           
          Rule 24(a)(4) provides:                                                     
               No entry of appearance by counsel not admitted to                      
               practice before this Court will be effective until                     
               counsel shall have been admitted, but counsel may be                   
               recognized as counsel in a pending case to the extent                  
               permitted by the Court and then only where it appears                  
               that counsel can and will be promptly admitted.  For                   
               the procedure for admission to practice before the                     
               Court, see Rule 200.                                                   
               Rule 200 restricts admission to practice before the Tax                
          Court to two classes of persons:  (1) Attorneys in good standing            
          of the Bar of the Supreme Court of the United States, or of the             
          highest or appropriate court of any State or of the District of             
          Columbia, or any commonwealth, territory, or possession of the              
          United States; and (2) applicants, not attorneys at law, who pass           
          a written examination given by the Tax Court as well as an                  
          additional oral examination if required by the Court.  This Court           
          has stated: “The requirement that only qualified persons are                
          permitted to represent litigants before this Court is for the               
          protection of litigants by insuring that only persons able to               
          properly represent a party appear for him.”  Cupp v.                        

          1  Section 7452 specifically provides that the taxpayer shall be            
          represented in accordance with the Rules of Practice and                    
          Procedure prescribed by this Court.  See sec. 301.7452-1, Proced.           
          & Admin. Regs.  Section 7452 further provides that “No qualified            
          person shall be denied admission to practice before the Tax Court           
          because of his failure to be a member of any profession or                  
          calling.”                                                                   




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