A taxpayer disputing an IRS finding of additional tax liability may initiate an action in the U.S. Tax Court. A taxpayer who has already paid a disputed tax and seeks a refund may file a claim in the U.S. District Court or the U.S. Claims Court. Decisions are appealed to the federal appellate court (in the case of claims court decisions, appeal is to the U.S. Court of Appeals for the Federal Circuit) and then to the Supreme Court. U.S. Tax Court decisions are either regular decisions or memorandum decisions (the latter usually do not involve an interpretation of the Code).
| Court | Reported | Binding Upon |
| Supreme Court | Supreme Court Reporter US Tax Cases |
Parties and as precedent for all courts |
| Courts of Appeals | Federal Reporter US Tax Cases |
Parties and as precedent for all courts in that circuit including cases before Tax Court |
| District Court/Court of Claims | Federal Supplement US Tax Cases |
Parties and as precedent for that district (including Tax Court) |
| Tax Court | Tax Court Reports Tax Court Memo |
Parties and as precedent in Tax Court (unless other Fed. Court decided). Tax Court Reports are cases of first impression. Tax Court Memo for cases where the issue is how to apply settled law. |
Source: Paul Callister, Federal Tax Hierarchies & Transactional Law Research, available here.