- (a) If the Tax Appeals Commission determines that a resolution of a threshold issue, such as a statute of limitations, may dispose of a case, the commission may bifurcate proceedings to hear and decide the threshold matter.
(b)
- (1) If the determination of the threshold issue does not resolve the case, then an order shall be issued, and the case shall proceed.
- (2) The determination of the threshold issue shall be explained in the subsequent decision on the merits under 26 CAR § 411-501.