“Review by the Supreme Court in federal tax cases - whether originating in the Tax Court in deficiency cases, or in the district courts or the Claims Court in refund cases - is ordinarily only by writ of certiorari . . . . Certiorari is granted in only a small proportion of the tax cases in which it is sought . . . .” Graetz, Federal Income Taxation: Principles and Policies, p. 84 (2nd ed. 1988) (Foundation Press).
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