In addition, our attorneys represent taxpayers in many pending cases before the United States Tax Court
, the federal district courts, the federal circuit courts of appeal, and the California Superior Court.
R, the Second Circuit addressed whether the United States Tax Court
and the District Court for the Southern District of New York properly applied the economic substance doctrine to transactions involving foreign tax credits.
The other Article I courts--the United States Tax Court
, United States Court of Veterans Appeals, and United States Court of Military Appeals--either exist as independent entities or receive administrative support from the executive branch.
United States Tax Court
, Press Release (June 26, 2012), available at http://www.
41) Thus, although which court hears the case is the taxpayer's "choice," over ninety-five percent of tax cases are heard by a judge in the United States Tax Court
because the financial incentive is so strong.
Of course, the simple answer is that Treasury does not enjoy jurisdiction in the United States Tax Court
and the Court can admit any person it judges worthy.
Their schemes are available to anyone willing to dig through the mountain of paperwork at United States Tax Court
and other government offices in search of nuggets of fact.
Many years ago, I was a practicing tax lawyer, and am still licensed to practice tax law before the United States Tax Court
and the United States Court of Claims.
Throughout his career, Jim Levy estimates he has served as an arbitrator and provided testimony in nearly 1,000 judicial matters in various courts, including the United States Tax Court
and state courts in New York, Connecticut, New Jersey, Missouri and Florida.
Memo 1997-470, the United States Tax Court
held that the distribution of a Florida widow's elective share was not subject to the provisions of Subchapter J.
In July 27, 1989, the United States Court of Appeals for the Sixth Circuit reversed, in part, the decision of the United States Tax Court
in Humana Inc.
District Court for the Southern District of Texas and in the United States Tax Court