There are five federal courts that have jurisdiction over disputes between taxpayers and the Government. All tax cases are first tried in one of three lower level trial courts: the United States Tax Court, the United States District Court, or the United States Court of Federal Claims. Tax cases tried in all of these courts are later appealed to the United States Courts of Appeals.
Although it is a national court, the Tax Court hears cases in different locations around the country, and appeals of Tax Court cases are heard by the U.S. Court of Appeals for the Circuit in which the taxpayer resides. Appeals of cases from District Courts are heard by the U.S. Court of Appeals for the Circuit in which they sit. Appeals from cases decided by the U.S. Court of Federal Claims are heard by the U.S. Court of Appeals for the Federal Circuit. In tax cases, as with all federal cases, the court of last resort is the United States Supreme Court.
If the taxpayer has not paid the tax, then the forum is the United States Tax Court. If the taxpayer has paid the disputed tax and is then refused a refund, the forum is either the federal district court (where he/she is entitled to a jury trial) or the Court of Federal Claims.
The following article describes the United States Tax Court operations and procedures.
