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The Phoenix And The Perils Of The Second Best: Why Heightened Appellate Deference To Tax Court Decisions Is Undesirable, Steve R. Johnson
The Phoenix And The Perils Of The Second Best: Why Heightened Appellate Deference To Tax Court Decisions Is Undesirable, Steve R. Johnson
Articles by Maurer Faculty
In our judicial structure, both courts of general jurisdiction and specialized courts are empowered to adjudicate federal income tax controversies. A proper relationship among those courts has proved difficult to forge and maintain. Absent an enduring intellectual and political consensus, institutional arrangements have been subject to recurring question and challenge.
The Tax Benefit Of Bliss, Alan L. Feld
The Tax Benefit Of Bliss, Alan L. Feld
Faculty Scholarship
In recent years the Supreme Court has limited its substantive decisions in federal income tax matters.I For the most part, the handful of tax cases it has considered each year deal with collection, liens, or other issues peripheral to doctrinal development in the tax area.2 The Court's recent decision in Diedrich v. Commissioner,3 however, dealt with a realization question involving net gifts; and its grant of certiorari consolidating the cases of Bliss Dairy, Inc. v. United States and Hillsboro National Bank v. Commissioner4 promises a continuing interest in substantive tax law. Bliss Dairy will enable the …