Tax Court signature-block notice applies beyond decision documents

Plain-English summary

Chief Counsel clarified the scope of Chief Counsel Notice 2025-003 for documents filed with the Tax Court. The notice applies to every document signed and dated after January 17, 2025, not only to decision documents. Decision documents remain subject to Tax Court Rule 23(a)(4), so the party's mailing address, email address, and telephone number must be omitted. For other Tax Court filings, Counsel employees must use the signature block specified in the notice. The advice resolves a document-formatting question rather than a substantive tax issue.

Ruling snapshot

• Question: Does Chief Counsel Notice 2025-003 apply only to Tax Court decision documents?
• Outcome: Advice given, the notice applies to all covered filings, with Rule 23(a)(4) still controlling decision documents
• Key authorities: Chief Counsel Notice 2025-003; Tax Court Rule 23(a)(4)

Full text (IRS public release)

ID: CCA_2025021110073000 [Third Party Communication:

UILC: 9999.00-00 Date of Communication: Month DD, YYYY]

Number: 202534002
Release Date: 8/22/2025
From: --------------------
Sent: Tuesday, February 11, 2025 10:07:30 AM
To: --------------------
Cc:
Bcc:
Subject: RE: Chief Memo CC-2025-003

Hi again,
I located the Chief Counsel Notice 2025-003 in my email. The Notice applies to all documents to be filed with the Tax Court that are signed and dated after January 17, 2025, not just decision documents. Thus, for decision documents, you must continue to follow T.C. Rule 23(a)(4) and omit the party’s mailing address, email address, and telephone number. For all other documents filed with the Tax Court, Counsel employees will use a signature block identical to the one in the Notice.

I hope this clarifies the matter. Please feel free to reach out if you have additional questions.

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