The U.S. Court of Appeals for the Sixth Circuit issued an opinion in a tax dispute that found the U.S. Tax Court is not a court as defined by law.

The case, Mobley v. Commissioner of Internal Revenue, involved an IRS audit of a couple's 2000 tax return in which the IRS increased their tax liability by $32,554. The Mobleys consented to the increased assessment and collection, then filed an amended tax return for 2000, claiming a refund of $27,715. The IRS audited that return as well and disallowed the claim because the couple failed to respond to requests for evidence supporting their claim.

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