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