Motion for Redetermination of Interest Overpayment

§ 7481. Date when Tax Court decision becomes final(a) Reviewable decisionsExcept as provided in subsections (b), (c), and (d), the decision of the Tax Court shall become final—(1) Timely notice of appeal not filedUpon the expiration of the time allowed for filing a notice of appeal, if no such notice has been duly filed within such time; or (2) Decision affirmed or appeal dismissed(A) Petition for certiorari not filed on timeUpon the expiration of the time allowed for filing a petition for certiorari, if the decision of the Tax Court has been affirmed or the appeal dismissed by the United States Court of Appeals and no petition for certiorari has been duly filed; or (B) Petition for certiorari deniedUpon the denial of a petition for certiorari, if the decision of the Tax Court has been affirmed or the appeal dismissed by the United States Court of Appeals; or (C) After mandate of Supreme CourtUpon the expiration of 30 days from the date of issuance of the mandate of the Supreme Court, if such Court directs that the decision of the Tax Court be affirmed or the appeal dismissed. (3) Decision modified or reversed(A) Upon mandate of Supreme CourtIf the Supreme Court directs that the decision of the Tax Court be modified or reversed, the decision of the Tax Court rendered in accordance with the mandate of the Supreme Court shall become final upon the expiration of 30 days from the time it was rendered, unless within such 30 days either the Secretary or the taxpayer has instituted proceedings to have such decision corrected to accord with the mandate, in which event the decision of the Tax Court shall become final when so corrected. (B) Upon mandate of the Court of AppealsIf the decision of the Tax Court is modified or reversed by the United States Court of Appeals, and if—(i) the time allowed for filing a petition for certiorari has expired and no such petition has been duly filed, or (ii) the petition for certiorari has been denied, or (iii) the decision of the United States Court of Appeals has been affirmed by the Supreme Court, then the decision of the Tax Court rendered in accordance with the mandate of the United States Court of Appeals shall become final on the expiration of 30 days from the time such decision of the Tax Court was rendered, unless within such 30 days either the Secretary or the taxpayer has instituted proceedings to have such decision corrected so that it will accord with the mandate, in which event the decision of the Tax Court shall become final when so corrected. (4) RehearingIf the Supreme Court orders a rehearing; or if the case is remanded by the United States Court of Appeals to the Tax Court for a rehearing, and if—(A) the time allowed for filing a petition for certiorari has expired and no such petition has been duly filed, or (B) the petition for certiorari has been denied, or (C) the decision of the United States Court of Appeals has been affirmed by the Supreme Court,