Davis, Robert Edwin
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Introduces a survey of Tax law cases from the United States Court of Appeals for the Fifth Circuit for the period from September 1, 1974, through August 31, 1975. The author gives a brief summary of the tax topics to be covered in the survey. The author notes that two general conclusions can be drawn from past Tax Court decisions. First, the Tax Court is a tribunal of growing dignity and competence, which has more recently demonstrated an objectivity that was lacking, at least in some measure, in its earlier decisions. Second, it has become increasingly difficult for taxpayers to prevail in cases taken to all of the courts of appeals, particularly that for the Fifth Circuit. However accurate the courts of appeals may be in their decisions on the merits, taxpayers' counsel must acknowledge the present statistical unlikelihood of success in the courts of appeals.