Internal Revenue Code Section 7443A(a)

Last week, the US Tax Court (Tax Court) announced that Chief Special Trial Judge (STJ) Peter J. Panuthos has decided to step down as Chief STJ, effective September 1, 2017. STJ Lewis R. Carluzzo will take over as Chief STJ beginning September 1, 2017. STJ Panuthos has been Chief STJ for the past 25 years, and has a long list of accomplishments, including assisting in the expansion of pro bono services to unrepresented taxpayers. The Tax Court’s press release provides more background on STJs Panuthos and Carluzzo.

STJs are an important part of the Tax Court, and perform many different functions for the Court. The statutory authority for STJs is found in Internal Revenue Code (Code) Section 7443A(a), which authorizes the Chief Judge of the Tax Court to appoint STJs. Code Section 7442A(b) provides that the Chief Judge may assign a variety of proceedings to be heard by STJs, any declaratory judgment proceeding, any proceeding under Code Section 7463 (relating to small tax case procedures), any proceeding where the amount in dispute does not exceed $50,000, lien/levy proceedings, certain employment status proceedings, whistleblower proceedings and any other proceedings which the Chief Judge may designate. Although STJs may potentially hear a wide variety of matters, most cases conducted by STJs related to small tax proceedings where the amount in dispute is less than $50,000. These cases are conducted as informally as possible and the rules of evidence are relaxed; however, the trade-off is that these types of cases are not appealable by either party and may not be treated as precedent for any other case (although there is no prohibition against citing such cases for their persuasive value). For more information on the statutory and Tax Court rules on STJs, see here.