This search page searches your selection of either the U.S. Tax Court Regular Opinions, Memorandum Opinions, Summary Opinions (decided under Section 7463 of the I.R.C. for small tax cases involving $10,000 or less), or all such opinions simultaneously.
“When the IRS determines a deficiency, the taxpayer can litigate the matter in any one of three courts: the Tax Court, a federal district court, or the Claims Court. [footnote omitted] If the first route is chosen, the taxpayer can litigate without paying in advance; to litigate in the district court or the Claims Court, the taxpayer must pay the tax, file a claim for refund, and then commence the law suit. [footnote omitted] . . . A taxpayer can appeal as of right from either the Tax Court or the district court to the court of appeals for the appropriate geographical circuit, whereas appeals from the Claims Court are to the Court of Appeals for the Federal Circuit. 4 B. Bittker & L Lokken, Federal Taxation of Income, Estates and Gifts, Par. 115.1 (2nd ed. 1992)