Ezel / IRS Rulings / 202417015
Chief Counsel Advice 202417015 Released April 26, 2024 Advice

DAWSON timing question turns on the Tax Court's EST-based rules

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This page covers one taxpayer's ruling from 2024, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

This brief Chief Counsel email raises a system-design question about how DAWSON should display or adjust filing dates and times. It asks whether the electronic Tax Court system should adjust those values to each user's time zone. The message notes that the Tax Court's rules are tied to Eastern Standard Time. It does not contain a conclusion or further legal analysis.

Ruling snapshot

  • Question: Should DAWSON adjust filing dates and times to the user's time zone when the Tax Court rules are tied to Eastern Standard Time?
  • Outcome: advice given, but no conclusion appears in the released email
  • Key authorities: Tax Court filing rules; UILC 7453.05-00

Full text (IRS public release)

 ID:        CCA_2024013109330707                           [Third Party Communication:

 UILC:      7453.05-00                                     Date of Communication: Month DD, YYYY]

Number: 202417015
Release Date: 4/26/2024
From: --------------------
Sent: Wednesday, January 31, 2024 9:33:07 AM
To: ----------------------------------------------------
Cc:
Bcc:
Subject: FW: [EXT] Dawson operating timezone


FYI—should DAWSON date/time adjustments be to the user’s time zone? The T.C. rules are
tied to EST.

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