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

Number
202417015
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Filing of All Documents
Code sections
§ 7453
Ruling dated
January 31, 2024
Publicly released
April 26, 2024

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2024, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, 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.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace