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Tax Lawyer, Vol. 55, No. 3 TAKING INSTITUTIONAL CHOICE SERIOUSLY 667 667 DEFERENTIAL REVIEW OF TAX COURT DECISIONS: TAKING INSTITUTIONAL CHOICE SERIOUSLY David F. Shores* “Institutional choice is difficult as well as essential.”1 I. INTRODUCTION For approximately the last 50 years, Tax Court decisions on questions of law have been subject to de novo review by the court of appeals for the circuit in which the taxpayer resides. Prior to that time, decisions were governed by a standard of...

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