26 C.F.R. § 1.1313(a)-1 Decision by Tax Court or other court as a determination.
Title 26 - Internal Revenue
(a) A determination may take the form of a decision by the Tax Court of the United States or a judgment, decree, or other order by any court of competent jurisdiction, which has become final. (b) The date upon which a decision by the Tax Court becomes final is prescribed in section 7481. (c) The date upon which a judgment of any other court becomes final must be determined upon the basis of the facts in the particular case. Ordinarily, a judgment of a United States district court becomes final upon the expiration of the time allowed for taking an appeal, if no such appeal is duly taken within such time; and a judgment of the United States Court of Claims becomes final upon the expiration of the time allowed for filing a petition for certiorari if no such petition is duly filed within such time. [T.D. 6500, 25 FR 12036, Nov. 26, 1960]
Title 26: Internal Revenue
PART 1—INCOME TAXES
Readjustment of Tax Between Years and Special Limitations
§ 1.1313(a)-1 Decision by Tax Court or other court as a determination.