Title 26Internal Revenue CodeRelease 119-73

§7460 Provisions of Special Application to Divisions

Title 26 › Subtitle Subtitle F— Procedure and Administration › Chapter 76— JUDICIAL PROCEEDINGS › Subchapter C— The Tax Court › Part II— PROCEDURE › § 7460

Last updated Apr 6, 2026|Official source

Summary

The Tax Court's chief judge can assign cases to divisions, smaller panels of the court. A division hears the case, decides it, and issues a report. That report automatically becomes the decision of the full Tax Court 30 days later, unless the chief judge orders full-court review within that window. Preliminary rulings by a division that do not decide the case are generally not reviewable by the full court, and a division's report is not part of the record when the chief judge sends a case for full review.

Full Legal Text

Title 26, §7460

Internal Revenue Code — Source: USLM XML via OLRC

(a)A division shall hear, and make a determination upon, any proceeding instituted before the Tax Court and any motion in connection therewith, assigned to such division by the chief judge, and shall make a report of any such determination which constitutes its final disposition of the proceeding.
(b)The report of the division shall become the report of the Tax Court within 30 days after such report by the division, unless within such period the chief judge has directed that such report shall be reviewed by the Tax Court. Any preliminary action by a division which does not form the basis for the entry of the final decision shall not be subject to review by the Tax Court except in accordance with such rules as the Tax Court may prescribe. The report of a division shall not be a part of the record in any case in which the chief judge directs that such report shall be reviewed by the Tax Court.

Reference

Citations & Metadata

Citation

26 U.S.C. § 7460

Title 26Internal Revenue Code

Last Updated

Apr 6, 2026

Release point: 119-73