Newspapers and tax publications have been busy highlighting major substantive changes in the tax laws brought about by the Taxpayer Relief Act of 1997. Less publicized are numerous changes to administrative and court procedures brought about by the Act. This special issue of our newsletter is devoted exclusively to discussing some of the more important procedural changes brought about by the Act.
Tax Court Jurisdiction Has Been Expanded in The Areas of Employment Taxes, Gift Tax Valuation Disputes, and Estate Tax Installment Payment Elections
Employment Tax Disputes.
Previously, the Tax Court did not have jurisdiction to hear cases involving an employer's liability for income tax withholding, FICA, or FUTA. Rather, employers had to pay some or all of those disputed taxes and proceed (after denial of their refund claims) to bring suit in their local United States district court or the United States Court of Federal Claims.
