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{{Organization
|OrganizationName=Tax Court
|OrganizationType=Judicial Branch (Specific Court)
|Mission=United States Tax Court resolves disputes between taxpayers and Internal Revenue Service, ensuring fair and accurate tax law application.
|ParentOrganization=Judicial Branch of the United States Government
|CreationLegislation=The Revenue Act of 1924; The Tax Court Reform Act of 1998
|Employees=200
|Budget=$52M (FY 2024)
|OrganizationExecutive=Chief Judge
|Services=Adjudication of federal income tax disputes; Pre-assessment review of tax cases; Small case procedures for disputes involving $50,000 or less; Regular trial sessions
|HeadquartersLocation=38.89561, -77.01474
|HeadquartersAddress=400 Second Street, NW, Washington, DC 20217, USA
|Website=https://www.ustaxcourt.gov/
}}
{{Short description|United States federal tribunal dealing with tax matters}}
{{Short description|United States federal tribunal dealing with tax matters}}
{{Use mdy dates|date=January 2018}}
{{Infobox U.S. federal court
| court_type      = tribunal
| court_name      = United States Tax Court
| abbreviation    = T.C.
| seal            = Seal of the United States Tax Court.svg
| seal_size      = 150
| courthouse      = [[United States Tax Court Building]]
| location        = [[Washington, D.C.]]
| appeals_to      = [[United States courts of appeals]] {{small|(Geographic circuits)}}
| established    = 1924
| authority      = Article I
| created_by      = [[Revenue Act of 1924]]<br>{{UnitedStatesCode|26|7441|7479}}
| composition    = [[President of the United States|Presidential]] nomination<br>with [[United States Senate|Senate]] [[advice and consent]]
| judges_assigned = 19
| term_length    = 15 years
| chief          = [[Kathleen Kerrigan (judge)|Kathleen Kerrigan]]
| official_site  = {{URL|https://www.ustaxcourt.gov/}}
}}
{{UStaxation}}


The '''United States Tax Court''' (in [[case citation]]s, '''T.C.''') is a [[Federal judiciary of the United States|federal]] [[trial court]] [[court of record|of record]] established by [[US Congress|Congress]] under [[Article One of the United States Constitution|Article I]] of the [[Constitution of the United States|U.S. Constitution]], section 8 of which provides (in part) that the Congress has the power to "constitute Tribunals inferior to the supreme Court".<ref>[[Article One of the United States Constitution|U.S. Constitution., article I]], section 8, cl. 9.</ref> The Tax Court specializes in adjudicating disputes over [[federal income tax]], generally prior to the time at which formal tax assessments are made by the [[Internal Revenue Service]].<ref>See {{usc|26|7441}}.</ref>
The '''United States Tax Court''' (in [[case citation]]s, '''T.C.''') is a [[Federal judiciary of the United States|federal]] [[trial court]] [[court of record|of record]] established by [[US Congress|Congress]] under [[Article One of the United States Constitution|Article I]] of the [[Constitution of the United States|U.S. Constitution]], section 8 of which provides (in part) that the Congress has the power to "constitute Tribunals inferior to the supreme Court".<ref>[[Article One of the United States Constitution|U.S. Constitution., article I]], section 8, cl. 9.</ref> The Tax Court specializes in adjudicating disputes over [[federal income tax]], generally prior to the time at which formal tax assessments are made by the [[Internal Revenue Service]].<ref>See {{usc|26|7441}}.</ref>
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In 1929, the United States Supreme Court ruled that the Board of Tax Appeals was not a "court," but was instead "an executive or administrative board, upon the decision of which the parties are given an opportunity to base a [[petition for review]] to the courts after the administrative inquiry of the Board has been had and decided."<ref>''Old Colony Trust Co. v. Commissioner'', 279 U.S. 716 (1929), at [https://scholar.google.com/scholar_case?q=%22279+U.S.+716%22&hl=en&as_sdt=3,44&case=6845680902173204894&scilh=0].</ref>
In 1929, the United States Supreme Court ruled that the Board of Tax Appeals was not a "court," but was instead "an executive or administrative board, upon the decision of which the parties are given an opportunity to base a [[petition for review]] to the courts after the administrative inquiry of the Board has been had and decided."<ref>''Old Colony Trust Co. v. Commissioner'', 279 U.S. 716 (1929), at [https://scholar.google.com/scholar_case?q=%22279+U.S.+716%22&hl=en&as_sdt=3,44&case=6845680902173204894&scilh=0].</ref>


In 1942, Congress passed the [[Revenue Act of 1942]], renaming the Board as the "Tax Court of the United States".<ref>Revenue Act of 1942, sec. 504(a), Pub. L. 753, Ch. 619, 56 Stat. 798, 957 (October 21, 1942).</ref> With this change, the Members became Judges and the Chairman became the Presiding Judge. By 1956, overcrowding and the desire to separate judicial and executive powers led to initial attempts to relocate the court. In 1962, [[United States Secretary of the Treasury|Secretary of the Treasury]] [[Douglas Dillon]] appealed to the [[General Services Administration]] (GSA) to incorporate funds for the design of a new building in its upcoming budget. The GSA allocated $450,000, and commissioned renowned architect [[Victor A. Lundy]], who produced a design that was approved in 1966.<ref name="GSA"/> However, funding constraints brought on by the [[Vietnam War]] delayed the start of construction until 1972.<ref name="GSA"/>
In 1942, Congress passed the [[Revenue Act of 1942]], renaming the Board as the "Tax Court of the United States".<ref>Revenue Act of 1942, sec. 504(a), Pub. L. 753, Ch. 619, 56 Stat. 798, 957 (October 21, 1942).</ref> With this change, the Members became Judges and the Chairman became the Presiding Judge. By 1956, overcrowding and the desire to separate judicial and executive powers led to initial attempts to relocate the court. In 1962, [[United States Secretary of the Treasury|Secretary of the Treasury]] [[Douglas Dillon]] appealed to the [[General Services Administration]] (GSA) to incorporate funds for the design of a new building in its upcoming budget. The GSA allocated $450,000, and commissioned renowned architect [[Victor A. Lundy]], who produced a design that was approved in 1966.<ref name="GSA"/> However, funding constraints brought on by the Vietnam War delayed the start of construction until 1972.<ref name="GSA"/>


The Tax Court was again renamed to its current formal designation in the [[Tax Reform Act of 1969]],<ref>{{cite web|url=http://www.library.unt.edu/search/google/govinfo%20law%20tutorial%20court%20courtspecial|title=Search|author=|date=|website=University of North Texas Libraries}}</ref> changing it from an historically administrative court to a full judicial court. The completed [[United States Tax Court Building]] was dedicated on November 22, 1974, the fiftieth anniversary of the Revenue Act that created the court.<ref name="GSA"/>
The Tax Court was again renamed to its current formal designation in the [[Tax Reform Act of 1969]],<ref>{{cite web|url=http://www.library.unt.edu/search/google/govinfo%20law%20tutorial%20court%20courtspecial|title=Search|author=|date=|website=University of North Texas Libraries}}</ref> changing it from an historically administrative court to a full judicial court. The completed [[United States Tax Court Building]] was dedicated on November 22, 1974, the fiftieth anniversary of the Revenue Act that created the court.<ref name="GSA"/>
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The Tax Court is composed of 19 judges appointed by the [[President of the United States|President]] and confirmed by the [[United States Senate|Senate]].<ref>See generally {{usc|26|7443}}(a) and (b).</ref> Former judges whose terms have ended may become "senior judges", able to return and assist the court by hearing cases while serving on recall. In addition, the court is assisted by a number of "special trial judges", who are employees of the court, appointed by the chief judge of the Tax Court, rather than by the President.<ref>{{usc|26|7443}}A (a).</ref> Special trial judges serve a function similar to that served by [[United States magistrate judge]]s of the [[United States district court|district courts]], and may hear cases regarding alleged deficiencies or overpayments of up to $50,000.<ref>{{usc|26|7443}}A (b)(3).</ref> Reappointment, when requested by a Tax Court judge (I.R.C. 7447(b)(3)) is generally ''[[pro forma]]'' regardless of the political party of the appointing President and the political party of the re-appointing (sitting) President.{{Citation needed|date=December 2007}} Each active judge appointed by the President has two [[law clerk]]s (attorney-advisers) and each senior judge and special trial judge has one law clerk.
The Tax Court is composed of 19 judges appointed by the [[President of the United States|President]] and confirmed by the [[United States Senate|Senate]].<ref>See generally {{usc|26|7443}}(a) and (b).</ref> Former judges whose terms have ended may become "senior judges", able to return and assist the court by hearing cases while serving on recall. In addition, the court is assisted by a number of "special trial judges", who are employees of the court, appointed by the chief judge of the Tax Court, rather than by the President.<ref>{{usc|26|7443}}A (a).</ref> Special trial judges serve a function similar to that served by [[United States magistrate judge]]s of the [[United States district court|district courts]], and may hear cases regarding alleged deficiencies or overpayments of up to $50,000.<ref>{{usc|26|7443}}A (b)(3).</ref> Reappointment, when requested by a Tax Court judge (I.R.C. 7447(b)(3)) is generally ''[[pro forma]]'' regardless of the political party of the appointing President and the political party of the re-appointing (sitting) President.{{Citation needed|date=December 2007}} Each active judge appointed by the President has two [[law clerk]]s (attorney-advisers) and each senior judge and special trial judge has one law clerk.


President [[George W. Bush]] was heavily criticized by the U.S. Congress, the Tax Bar, and others when he indicated that he likely would not, or might not, re-appoint Tax Court judges whose terms were expiring (even though the first judge whose re-appointment President Bush called into question, Judge John O. Colvin, was appointed by President [[Ronald Reagan]]).{{Citation needed|date=December 2007}} President [[Bill Clinton]] also was criticized for not acting timely to re-appoint Tax Court judges, having allowed one sitting Chief Judge's term to expire, thus requiring the Tax Court to elect a new Chief Judge. Additionally, several Tax Court judges had to wait more than a year (sometimes more than two years) to be reappointed during the Clinton presidency.{{Citation needed|date=December 2007}}
President George W. Bush was heavily criticized by the U.S. Congress, the Tax Bar, and others when he indicated that he likely would not, or might not, re-appoint Tax Court judges whose terms were expiring (even though the first judge whose re-appointment President Bush called into question, Judge John O. Colvin, was appointed by President [[Ronald Reagan]]).{{Citation needed|date=December 2007}} President [[Bill Clinton]] also was criticized for not acting timely to re-appoint Tax Court judges, having allowed one sitting Chief Judge's term to expire, thus requiring the Tax Court to elect a new Chief Judge. Additionally, several Tax Court judges had to wait more than a year (sometimes more than two years) to be reappointed during the Clinton presidency.{{Citation needed|date=December 2007}}


Trial sessions are conducted and other work of the Court is performed by its judges, by senior judges serving on recall, and by special trial judges. All of the judges have expertise in the tax laws, and are tasked to "apply that expertise in a manner to ensure that taxpayers are assessed only what they owe, and no more". Although the "principal office" of the Court is located in the [[District of Columbia]], Tax Court judges may sit "at any place within the United States".<ref>See {{usc|26|7445}}.</ref> The judges travel nationwide to conduct trials in various designated cities. The work of the Tax Court has occasionally been interrupted by events. In 2001, a trial session in [[New York City]] was canceled due to the [[September 11 attacks|September 11 terrorist attacks]]. In 2005, stops in [[Miami]] and [[New Orleans]] were canceled due to the effects of hurricanes which had struck shortly before their scheduled visit to each city.{{Citation needed|date=December 2007}}
Trial sessions are conducted and other work of the Court is performed by its judges, by senior judges serving on recall, and by special trial judges. All of the judges have expertise in the tax laws, and are tasked to "apply that expertise in a manner to ensure that taxpayers are assessed only what they owe, and no more". Although the "principal office" of the Court is located in the [[District of Columbia]], Tax Court judges may sit "at any place within the United States".<ref>See {{usc|26|7445}}.</ref> The judges travel nationwide to conduct trials in various designated cities. The work of the Tax Court has occasionally been interrupted by events. In 2001, a trial session in New York City was canceled due to the [[September 11 attacks|September 11 terrorist attacks]]. In 2005, stops in [[Miami]] and [[New Orleans]] were canceled due to the effects of hurricanes which had struck shortly before their scheduled visit to each city.{{Citation needed|date=December 2007}}


The Tax Court's judges serve 15-year terms, subject to presidential removal during the term for "[I]nefficiency, neglect of duty, or malfeasance in office."<ref>26 U.S.C. 7443(f)</ref> The mandatory retirement age for judges is 70.<ref>26 U.S.C. 7447.</ref> The judges' salaries are set at the same rate as "[J]udges of the district courts of the United States",<ref>26 U.S.C. 7443(c)(1)</ref> currently $243,300 annually.<ref>Judicial Compensation Available ''https://www.uscourts.gov/judges-judgeships/judicial-compensation''.</ref>
The Tax Court's judges serve 15-year terms, subject to presidential removal during the term for "[I]nefficiency, neglect of duty, or malfeasance in office."<ref>26 U.S.C. 7443(f)</ref> The mandatory retirement age for judges is 70.<ref>26 U.S.C. 7447.</ref> The judges' salaries are set at the same rate as "[J]udges of the district courts of the United States",<ref>26 U.S.C. 7443(c)(1)</ref> currently $243,300 annually.<ref>Judicial Compensation Available ''https://www.uscourts.gov/judges-judgeships/judicial-compensation''.</ref>
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