U.S. Appeals Court Dismisses Taxpayer’s Appeal of Tax Court Order for Lack of Jurisdiction

The U.S. Court of Appeals for the Sixth Circuit dismissed a taxpayer’s appeal of a Tax Court order for lack of jurisdiction because the Tax Court order was not a dismissal or a determination of a deficiency. The taxpayer filed a Tax Court petition alleging due process violations in connection with tax collection and seeking an abatement of interest. The Commissioner sought to dismiss the interest abatement claim for lack of an administrative determination, which the Tax Court granted. The case remained before the Tax Court as to the tax collection due process violation claim, while the Tax Court remanded ...