Title 26 — Internal Revenue CodeRelease 119-73

§7458 Hearings

Title 26 › Subtitle Subtitle F— - Procedure and Administration › Chapter CHAPTER 76— - JUDICIAL PROCEEDINGS › Subchapter Subchapter C— - The Tax Court › Part PART II— - PROCEDURE › § 7458

Last updated Apr 6, 2026|Official source

Summary

The Tax Court must give both the taxpayer and the Secretary (the government's tax official) notice and a chance to be heard in any case it starts. If a Tax Court division already held a hearing, neither side gets another hearing in the full Tax Court on review unless the chief judge orders one. Hearings are open to the public, testimony (and, if the court wants, arguments) must be recorded by a court reporter, and the court may hire contractors to make the transcripts and set the rules for who gets copies.

Full Legal Text

Title 26, §7458

Internal Revenue Code — Source: USLM XML via OLRC

Notice and opportunity to be heard upon any proceeding instituted before the Tax Court shall be given to the taxpayer and the Secretary. If an opportunity to be heard upon the proceeding is given before a division of the Tax Court, neither the taxpayer nor the Secretary shall be entitled to notice and opportunity to be heard before the Tax Court upon review, except upon a specific order of the chief judge. Hearings before the Tax Court and its divisions shall be open to the public, and the testimony, and, if the Tax Court so requires, the argument, shall be stenographically reported. The Tax Court is authorized to contract (by renewal of contract or otherwise) for the reporting of such hearings, and in such contract to fix the terms and conditions under which transcripts will be supplied by the contractor to the Tax Court and to other persons and agencies.

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Amendments

1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” and struck out “nor his delegate” after “nor the Secretary”.

Reference

Citations & Metadata

Citation

26 U.S.C. § 7458

Title 26 — Internal Revenue Code

Last Updated

Apr 6, 2026

Release point: 119-73