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He also notes "an undertone in much of the opposition [to a national court of tax appeals]: a suspicion that a tax appellate court would be pro-government in outlook and tendency." [26] Professor Andre Smith, however, argues that the perception that the Tax Court has a pro-government bias is a threat to the legitimacy of the tax system. [27]
Similarly, section 7482 of the Internal Revenue Code provides that the U.S. Supreme Court and the U.S. Courts of Appeals may impose penalties in which the taxpayer's appeal of a U.S. Tax Court decision was "maintained primarily for delay" or where "the taxpayer's position in the appeal is frivolous or groundless."
Which he stated "is problematic, because these terms are not synonymous. The bond required to perfect an appeal is a cost bond, which is sometimes referred to as an appeal bond. The bond required to obtain a stay of execution of a judgment while the judgment is being appealed is a supersedeas bond, also referred to as an appeal bond." [9]
Commissioner of Internal Revenue, 54 T.C. 742 (1970), [1] aff'd on other grounds, 445 F.2d 985 (10th Cir. 1971), [2] cert. denied, 404 U.S. 940 (1971), [3] is a case in which the United States Tax Court stated the principle that where the court of appeals to which an appeal would be made in a given case has already established a rule of ...
President Calvin Coolidge signing the income tax bill which established the U.S. Board of Tax Appeals; Andrew Mellon is the third figure from the right.. The first incarnation of the Tax Court was the "U.S. Board of Tax Appeals", established by Congress in the Revenue Act of 1924 [4] [5] (also known as the Mellon tax bill) in order to address the increasing complexity of tax-related litigation.
It is within the discretion of the court to assign and impose costs for a continuance in a civil case. Extensive case law reviewed. [139] As a condition to granting a continuance, a court may require a plaintiff to a file a bond securing a payment of all court costs incurred. [140] [141]
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The majority of cases are decided by a settlement. Both sides (regardless of relative monetary resources) often have a strong incentive to settle to avoid the costs (such as legal fees, finding expert witnesses, etc.), the time and the stress associated with a trial, particularly where a trial by jury is available.