Tax-Court
The Six Exits Applied: How the Real Exits Actually Operate in Everyday Enforcement
Six exits gamed against ten everyday government encounters — speeding tickets to bench-warrant escalations. Exit 6 (force the system to perform on its own procedural mechanisms) is the sweet spot for seven of ten and the accessible component in the other three. The single most actionable finding is the timing rule: Exit 6's cost ratio inverts as the enforcement ratchet advances. Respond early, respond through the system's machinery, or lose.
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.
Texas State Criminal — Type B Bifurcated
The Texas state criminal track is structurally distinctive: a bifurcated apex (Court of Criminal Appeals for criminal matters; Texas Supreme Court for civil), and a de novo retrial at the County Court at Law level that resets all preservation obligations. This page maps the five-court path with full receiver profiles, transition mechanics, and the four-lens matrix.
Article III vs. Article I Courts: What Kind of Authority?
The federal courts are not a single category. Article III courts exercise 'the judicial Power of the United States' under structural protections the Constitution requires. Article I courts are creatures of Congress with fixed-term judges and statutorily-defined jurisdiction. The distinction is consequential — and underexamined.
How Courts Respond: The Sanction Regime and the Doctrine of Non-Engagement
When litigants raise alternate tax theories, federal courts don't just rule against them — they refuse to reason about them. This essay examines the Crain doctrine, §6673 penalties, and what 'frivolous' actually means in practice.
Article I Court
A federal tribunal created by Congress under its Article I legislative power rather than under Article III. Judges serve fixed terms; jurisdiction is statutorily defined and revisable. The Tax Court, bankruptcy courts, and Court of Federal Claims are the leading examples.