Chapter 5

A trial-level court that hears only cases involving tax issues. Issues regular and memorandum decisions. Meets in Washington, D.C., and in other major cities. Formerly called the Board of Tax Appeals.

An earlier name for the U.S. Tax Court, which did not have full judicial status. Opinions are recorded in the ... of ... ... reporter, the citation abbreviation for which is BTA.

When the Tax Court reaches a decision without calculating the tax, the decision is said to be entered under ... ....

A decision issued by the Tax Court that generally involves a new or unusual point of law, as determined by the chief judge of the court.

A decision of the Tax Coutr that, in the opinion of the chief judge, does not address a new or unusual issue of tax law. While generally not considered as important as regular Tax Court decisions, ... ... should nonetheless not be ignored by researchers.

Located throughout the U.S., LITCs are staffed by volunteers who are admitted to practice before the Tax Court. In addition to representing ...-... ... in audits, appeals, and collection disputes, and can help taxpayers respond to IRS notices and to correct account problems.

Tax Court decisions are appealed to the federal court of appeals for the taxpayer's place of work or residence. The decisions of the courts of appeal are not always consistent. Under the ... ..., when a taxpayer whose circuit has ruled on a given issue brings a case that includes that issue before the Tax Court, the Tax Court follows the holding of the pertinent circuit, even if the Tax Court disagrees with the holding, or if another circuit has issued a contrary holding. This can lead to contradictory Tax Court rulings based solely on the state of the taxpayer's residence.

A devision of the Tax Court that can try cases of taxpayers whose disputed tax liability does not exceed $50,000. Procedural rules of the division are somewhat relaxed, and taxpayers often represent themselves. ... ... ... decisions are not published, nor can either party appeal the division's holdings.

Tax Court small tax case decisions, called summary opinions, are not officially published by the government, but are available from commercial publishers. Small tax case decisions cannot be used as precedent when dealing with the IRS. However, they do provide insight into how the Tax Court has treated similar tax situations.

A Tax Court citation assigned to a Tax Court decision; contains the case name, volume number, reporter, case number, and year of the decision. The page number is not included because the opinion has not yet been published.

A Tax Court citation assigned to a Tax Court decision; contains the case name, volume number, reporter page number, and year of the decision.

A trial-level court that hears tax and nontax cases. Organized according to geographical regions. Jury trials are available.

The citation abbreviation for the tax case reporter, ... ... ... .... The first series of the reporter includes cases concerning pre-1954 Internal Revenue Code litigation, and the second and third series include cases that address issues relative to the 1954 and 1986 codes, respectively. Includes most tax case opinions issued by federal courts other than the Tax Court.

The citation abbreviation for the Commerce Clearing House reporter, U.S. Tax Cases. Includes most of the tax decisions of federal courts other than the Tax Court.

A trial-level court in which the taxpayer typically sues the government for a refund of overpaid tax liability. Hears nontax matters as well in Washington, D.C., or in other major cities.

A federal appellate court that hears appeals from the Tax Court, Court of Federal Claims, and district courts within its geographical circuits, although there are additional circuits for Washington, D.C., and for cases appealed from the Court of Federal Claims.

The highest federal appellate court, which hears very few tax cases. The court approves a writ of certiorari for the cases that it hears.

Document issued by the U.S. Supreme Court, indicating the Court will hear the petitioned case. If the case will not be heard, certiorari is said to be denied.

Numbered paragraphs in which the editors of the current court reporter summarize the court's holdings on each issue. These paragraphs appear in the court reporters before the text of the actual court case.

A concise summary of the facts, issues, holdings, and analyses of a court case. Used in a tax research context to allow subsequent review of the case by its author or another party. Includes complete citations of the ... ... and other items addressed in the ... to facilitate additional review when necessary.