Document Type


Publication Date


Publication Title

Oklahoma Law Review


Tax Court, National Court of Tax Appeals, Internal Revenue Service, IRS


This article examines the Tax Court and the Internal Revenue Service. Part I discusses the structural and decision-making evolution of the Tax Court as well as the most common recommendation for change--the creation of a National Court of Tax Appeals. Part II examines the nonacquiescence practice of the Internal Revenue Service and the current state of the law with respect to intracircuit nonacquiescence. The article concludes that an expanded concept of stare decisis can alleviate many of the problems without the massive structural change entailed in the creation of a National Court of Tax Appeals.

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Tax Law Commons