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Is The United States Tax Court Exempt From Administrative Law Jurisprudence When Acting As A Reviewing Court?, Diane Fahey

Diane L. Fahey

To maintain legitimacy and stability, a government must have access to a reliable source of revenue. Taxes are the lifeblood that sustains a government. Therefore, as far back as 1931, the United States Supreme Court has enforced the principle that the executive branch of the federal government must be unimpaired in its ability to collect taxes owed; otherwise, the government could be undermined by citizens who attempt to delay or evade their obligation to pay taxes.

Taxpayers have always been permitted to dispute the amount of their liability; however, until recently, taxpayers had little opportunity to dispute the method employed …