firmly bound unto the above-named COMMISSIONER OF INTERNAL REVENUE and/or the UNITED STATES OF AMERICA, in the sum of $(double the deficiency or

such sum as the Tax Court has fixed upon petitioner's prior motion), to be paid to the said Commissioner of Internal Revenue and/or the United States of America for the payment of which well and truly to be made we bind ourselves and each of us and our successors and assigns jointly and severally firmly by these presents. day

of

Signed, sealed, and dated this 19-.

WHEREAS, the above named

is filing or is about to file with the United States Tax Court, an appeal from the said Court's decision in respect to the tax liability of the above petitioner for the taxable year or yearsby the United States Court of Appeals for the-Circuit to reverse the decision rendered in the above-entitled cause.

--

NOW, THEREFORE, the condition of this Obligation is such that if the above-named ---shall file its appeal and shall prosecute said appeal to effect and shall pay the deficiency as finally determined, together with any interest, additional amounts or additions to the tax provided for by law, then this obligation shall be void, otherwise the same shall be and remain in full force and virtue.

[SEAL]

of

Signed, sealed, and dated this

19-.

WHEREAS, the above-named

-day

-is

filing or is about to file with the United States Tax Court, an appeal from the said Court's decision in respect of the tax liability of the above petitioner for the taxable year or years

-by the United States Court of Appeals for the--— -Circuit to reverse the decision rendered in the above-entitled cause. NOW, THEREFORE, the condition of this obligation is such that if the above-named shall file its appeal and shall prosecute said appeal to effect and shall pay the deficiency as finally determined, together with any interest, additional amounts or additions to the tax provided for by law, then this obligation shall be void, otherwise the same shall be and remain in full force and virtue.

The above-bounden obligor, in order the more fully to secure the Commissioner of Internal Revenue and/or the United States in the payment of the aforementioned sum, hereby pledges as security therefor bonds/notes of the United States in a sum equal at their par value to the aforementioned sum, to wit:-dollars -), which said bonds/notes are numbered serially and are in the denominations and amounts, and are otherwise more particularly described as follows:

which said bonds/notes have this day been deposited with the Clerk of the United States Tax Court and his receipt taken therefor.

Contemporaneously herewith the undersigned has also executed and delivered an irrevocable power of attorney and agreement in favor of the Clerk of the United States Tax Court, authorizing and empowering him, as such attorney to collect or sell or transfer or assign, the above-described bonds/notes so deposited, or any part thereof, in case of any de

Secretary

FORM 11

Title

POWER OF ATTORNEY AND AGREEMENT BY CORPORATION

(See Rule 191)

office in the city of

KNOW ALL MEN BY THESE PRESENTS: That a corporation duly incorporated under the laws of the State of and having its principal State of in pursuance of a resolution of the Board of Directors of said corporation, passed on the day of ——, 19—, a duly certified copy of which resolution is hereto attached, does hereby constitute and appoint the Clerk of the United States Tax Court as attorney for said corporation, for and in the name of said corporation to collect or to sell, assign, and transfer certain United States Liberty bonds or other bonds or notes of the United States, the property of said corporation, described as follows:

such bonds/notes having been deposited by it, pursuant to the Act of July 30, 1947, c. 390, 61 Stat. 646, as security for the faithful performance of any and all of the conditions or stipulations of a certain obligation entered into by it with (here enter "the Commissioner of Internal Revenue and/or the United States") under date ofwhich is hereby made a part thereof, and the undersigned agrees, that, in case of any default in the performance of any of the conditions and stipulations of such undertaking, its said attorney shall have full power to collect said bonds/notes or any part thereof, or to sell, assign, and transfer said bonds/notes or any part thereof without notice, at public or private sale, or to transfer or assign to another for the purpose of effecting either public or private sale, free from any equity of

redemption and without appraisement or valuation, notice and right to redeem being waived, and the proceeds of such sale or collection, in whole or in part to be applied to the satisfaction of any damages, demands, or deficiency arising by reason of such default, as may be deemed best, and the undersigned further agrees that the authority herein granted is irrevocable.

And said corporation hereby for itself, its successors and assigns, ratifies and confirms whatever its said attorney shall do by virtue of these presents.

61 Stat. 646, as security for the faithful performance of any and all of the conditions or stipulations of a certain obligation entered into by me (us) with (here enter "the Commissioner of Internal Revenue and/or the United States") under date of which is hereby made a part thereof, and I (we), agree that, in case of any default in the performance of any of the conditions and stipulations of such undertaking, my (our) said attorney shall have full power to collect said bonds/notes or any part thereof, or to sell, assign, and transfer said bonds/notes or any part thereof without notice, at public or private sale, or to transfer or assign to another for the purpose of effecting either public or private sale, free from any equity of redemption and without appraisement or valuation, notice and right to redeem being waived, and the proceeds of such sale or collection, in whole or in part to be applied to the satisfaction of any damages, demands, or deficiency arising by reason of such default, as may be deemed best, and I (we) further agree that the authority herein granted is irrevocable.

And for myself (ourselves), my (our several) administrators, executors, and assigns, I (we) hereby ratify and confirm whatever my (our) said attorney shall do by virtue of these presents.

In witness whereof, I (we) hereinabove named, have executed this instrument and affixed my (our) seal this--day of19-.

State of

seal

County of

-[SEAL]

SS:

Notary Public

My Commission expires

FORM 12

APPENDIX II

Code Section 7463

DISPUTES INVOLVING $5,000 OR LESS

(See Rules 170 through 179)

(a) IN GENERAL.-In the case of any petition filed with the Tax Court for a redetermination of a deficiency where neither the amount of the deficiency placed in dispute, nor the amount of any claimed overpayment, exceeds

(1) $5,000 for any one taxable year, in the case of the taxes imposed by subtitle A,

(2) $5,000, in the case of the tax imposed by chapter 11, or

(3) $5,000 for any one calendar year, in the case of the tax imposed by chapter 12,

at the option of the taxpayer concurred in by the Tax Court or a division thereof before the hearing of the case, proceedings in the case shall be conducted under this section. Notwithstanding the provisions of section 7453, such proceedings shall be conducted in accordance with such rules of evidence, practice, and procedure as the Tax Court may prescribe. A decision, together with a brief summary of the reasons therefor, in any such case shall satisfy the requirements of sections 7459(b) and 7460.

(b) FINALITY OF DECISIONS.-A decision entered in any case in which the proceedings are conducted under this section shall not be reviewed in any other court and shall not be treated as a precedent for any other case.

(c) LIMITATION OF JURISDICTION.-In any case in which the proceedings are conducted under this section, notwithstanding the provisions of sections 6214(a) and 6512(b), no decision shall be entered redetermining the amount of a deficiency, or determining an overpayment, except with respect to amounts placed in dispute within the limits described in subsection (a) and with respect to amounts conceded by the parties.

(d) DISCONTINUANCE OF PROCEEDINGS.-At any time before a decision entered in a case in which the proceedings are conducted under this section becomes final, the taxpayer or the Secretary or his delegate may request that further proceedings under this section in such case be discontinued. The Tax Court, or the division thereof hearing such case, may, if it finds that (1) there are reasonable grounds for believing that the amount of the deficiency placed in dispute, or the amount of an overpayment, exceeds the applicable jurisdictional amount described in subsection (a), and (2) the amount of such excess is large enough to justify granting such request, discontinue further proceedings in such case under this section. Upon any such discontinuance, proceedings in such case shall be conducted in the same manner as cases to which the provisions of sections 6214(a) and 6512(b) apply.

(e) AMOUNT OF DEFICIENCY IN DISPUTE.-For purposes of this section, the amount of any deficiency placed in dispute includes additions to the tax, additional amounts, and penalties imposed by chapter 68, to the extent that the pro

Louisiana: New Orleans.

Maryland: Baltimore.

Massachusetts: Boston.
Michigan: Detroit.

Minnesota: St. Paul.

Mississippi: Biloxi, Jackson.

Missouri: Kansas City, St. Louis.

Montana: Helena.

Nebraska: Omaha.

Nevada: Las Vegas/Reno.

New Jersey: Newark.

New Mexico: Albuquerque.

New York: Buffalo, New York City. North Carolina: Greensboro/Durham. Ohio: Cleveland, Cincinnati, Columbus. Oklahoma: Oklahoma City, Tulsa. Oregon: Portland.

Pennsylvania: Philadelphia, Pittsburgh.
South Carolina: Columbia.

Tennessee: Knoxville, Memphis, Nashville. Texas: Dallas, El Paso, Houston, Lubbock, San Antonio.

Utah: Salt Lake City.

Virginia: Richmond.

Washington: Seattle, Spokane.

West Virginia: Charleston/Huntington. Wisconsin: Milwaukee.

The Court sits in about 35 other cities to hear Small Tax Cases. A list of such cities is contained in a pamphlet entitled "Election of Small Tax Case Procedure and Preparation of Petitions," a copy of which may be obtained from the Clerk of the Court.