Which rule or statute governs the 30-day period to appeal after an FDDA?

Which rule or statute governs the 30-day period to appeal after an FDDA?

• A. Sec. 223 NIRC
• B. Sec. 228 NIRC
• C. RR 18-13
• D. Sec. 228 NIRC; RR 18-13

Answer: (D)

The time limit to appeal a FDDA is set by both the enabling law and the implementing rules. Section 228 of the National Internal Revenue Code establishes the 30-day deadline to file an appeal with the Court of Tax Appeals, counting from when the FDDA is received. But the way that period is computed and the steps to perfect the appeal are laid out in Revenue Regulation 18-13. RR 18-13 provides the procedural details—how receipt is determined, how to count days, and the proper filing requirements. So the correct understanding comes from both sources: Sec. 228 NIRC for the deadline, and RR 18-13 for the computation and filing rules.

The time limit to appeal a FDDA is set by both the enabling law and the implementing rules. Section 228 of the National Internal Revenue Code establishes the 30-day deadline to file an appeal with the Court of Tax Appeals, counting from when the FDDA is received. But the way that period is computed and the steps to perfect the appeal are laid out in Revenue Regulation 18-13. RR 18-13 provides the procedural details—how receipt is determined, how to count days, and the proper filing requirements. So the correct understanding comes from both sources: Sec. 228 NIRC for the deadline, and RR 18-13 for the computation and filing rules.