On behalf of the Section of Taxation (“Section”) of the American Bar Association, the following comments are provided in response to the invitation for public comments issued by the United States Tax Court (the “Court”) with respect to proposed amendments to the Court’s Rules of Practice and Procedure announced on December 20, 2010.1 The proposed amendments include amendments concerning timing for filing summary judgment motions, Rule 1552 computations, motions regarding elections to proceed under the small tax case procedure, answers in lien and levy cases, and recognition of mediation as a form of alternative dispute resolution. These comments have not been approved by the House of Delegates or Board of Governors of the American Bar Association and, accordingly, they should not be construed as representing the position the American Bar Association