26 CAR § 411-407. Bifurcation of proceedings

(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.