Federal-Tax

Federal Tax — IRS, Tax Court, and Refund Litigation

The federal tax track is structurally unlike any state track because it splits at the moment of assessment into two parallel paths with different Article I / Article III profiles. The fork is determined by a single decision: pay the disputed tax before litigating, or not? That decision determines whether a jury trial is available, the institutional character of the first judicial decision-maker, the tradition-lens profile of the proceeding, and the appellate route.