Section 7477: Declaratory judgments relating to value of certain gifts
Internal Revenue Code
§7477. Declaratory judgments relating to value of certain gifts
(a) Creation of remedy
In a case of an actual controversy involving a determination by the Secretary of the value of any gift shown on the return of tax imposed by
(2) Exhaustion of administrative remedies
The court shall not issue a declaratory judgment or decree under this section in any proceeding unless it determines that the petitioner has exhausted all available administrative remedies within the Internal Revenue Service.
(3) Time for bringing action
If the Secretary sends by certified or registered mail notice of his determination as described in subsection (a) to the petitioner, no proceeding may be initiated under this section unless the pleading is filed before the 91st day after the date of such mailing.
A prior section 7477, added
Section applicable to gifts made after Aug. 5, 1997, see section 506(e)(1) of