U.S. Tax Court

The United States Tax Court is an Article I court created by Congress to provide an independent judicial forum where taxpayers may challenge determinations made by the Internal Revenue Service (IRS) before paying the disputed tax liability. Its origins trace to the Board of Tax Appeals (1924), later reconstituted as the Tax Court of the United States, and finally established in its present form under the Internal Revenue Code. The Tax Court has exclusive jurisdiction over many federal tax controversies, including income, estate, gift, and certain excise taxes, as well as related penalties and deficiencies asserted by the IRS. Unlike Article III courts, the Tax Court is not a general trial court; its jurisdiction is strictly statutory and limited to matters Congress has placed under its authority. Judges of the Tax Court are appointed by the President with Senate confirmation for 15-year terms, and they may be reappointed. Proceedings in the court are bench trials—there are no juries—and they are governed by procedures designed to balance efficiency with fairness, including simplified procedures for smaller claims. Decisions of the Tax Court are appealable to the appropriate U.S. Court of Appeals, depending on the taxpayer’s residence, and ultimately may be reviewed by the Supreme Court of the United States. The Tax Court plays a crucial role in ensuring due process within the federal tax system, providing taxpayers a fair opportunity to contest IRS assessments without first having to satisfy them financially.