Substance of the R4C

[LearnTheLaw]

all this came on a document with no seal and unsigned!

If this document is unsigned and without an official seal, is it even a legal document???

Doesn't the IRS operate with deception?

[gdude]

LTL, Thank you very much...that was exactly my point.

[TDL]

Ime (rather limited, I must admit) TC memos are not issued under Official Seal, nor signed. After looking over @ Thornberry and Mooney once again (among others), the pattern becomes quite clear. Not surprisingly, I learned that the statutory context for TC memos derives from IRC 7459 and 7460. Specifically, we're looking @ 7459(b) which provides the looked-for "backdoor" to the TC, the proverbial escape-hatch for keeping its "findings of fact ..." out of the official record, to wit:

... Subject to such conditions as the Tax Court may by rule provide, the requirements of this subsection and of section 7460 are met if findings of fact or opinion are stated orally and recorded in the transcript of the proceedings.

Imho, unless you get the actual transcript (more expenses!) of the judges/panels-proceeding, you won't really know what facts / evidence the judge(s) based the ruling on. Lastly, the TC's final order should be issued under both TC-Seal & judge-signature, along with a CoS (Certificate of Service) by the Clerk.