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The notice states that taxpayers have 30 days from the date of the notice of determination to appeal the decision to the Tax Court or, if the Tax Court does not have jurisdiction over the underlying tax liability, to a Federal district court. As a prerequisite for seeking Tax Court review, a taxpayer must have received a Notice of Determination from the IRS that informs the taxpayer of the opportunity to seek Tax Court review and provides information on how to do so. Withdrawing the Notice of Determination was the strategy the State of California chose to scuttle the anti-710 litigation and we respect any action by Caltrans that moves the process forward," said Read. |
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