26 U.S.C. § 7482 — Courts of review

(a) Jurisdiction: (1) In general: the U.S. Courts of Appeals (except the Federal Circuit) have exclusive power to review Tax Court decisions, the same way they review civil trial court cases decided without a jury - except as 28 U.S.C. § 1254 allows. That Court of Appeals decision is final, but the Supreme Court can still review it through a certiorari petition under the same section. (2)(A) Interlocutory orders: if a Tax Court judge says, in a mid-case order, that a major legal question is genuinely disputed and that an immediate appeal could speed up the case's resolution, the Court of Appeals can - at its discretion - allow an appeal from that order, if asked within 10 days of the order. Neither asking for, nor getting, this kind of appeal automatically pauses the Tax Court case, unless a Tax Court judge or the Court of Appeals orders a pause. (B) For purposes of (b) and (c), this kind of order counts as a Tax Court decision. (C) If a Court of Appeals allows this kind of appeal, any later review of the case (except as (b)(2) provides) goes to that same Court of Appeals. (3) Certain orders under section 6213(a): a Tax Court order under section 6213(a) that resolves a request to stop an assessment or collection counts as a Tax Court decision for this section, and can be reviewed by the Court of Appeals the same way a similar district court order can. (b) Venue: (1) Generally, the right Court of Appeals depends on the type of case: (A) for an individual disputing their tax bill, it is the circuit where they legally live; (B) for a corporation, it is the circuit of its main place of business, or if none, the circuit where its tax return was filed; (C) for someone seeking a declaratory decision under section 7476, it is the circuit of the employer's main place of business; (D) for an organization seeking a declaratory decision under section 7428, it is the circuit of the organization's main office; (E) for a partnership case under section 6234, it is the circuit of the partnership's main place of business; (F) for a case under section 6015(e), it is the circuit where the petitioner legally lives; and (G) for a case under section 6320 or 6330, it is (i) the petitioner's home circuit if an individual, or (ii) the circuit of their main place of business if an entity. If none of these fit, the case goes to the Court of Appeals for the District of Columbia. Residence or place of business is measured as of when the case was filed with the Tax Court. (2) By agreement: instead of following (1), the IRS and the taxpayer can agree in writing to have any Court of Appeals review the case. (3) Declaratory judgment cases about certain government obligations: a Tax Court decision under section 7478 can only be reviewed by the Court of Appeals for the District of Columbia. (c) Powers: (1) To affirm, modify, or reverse: the reviewing court can affirm the Tax Court's decision, or - if it was not decided in accordance with law - modify or reverse it, with or without sending it back for a new hearing, as fairness requires. (2) To make rules: rules for reviewing Tax Court decisions are the ones the Supreme Court sets under 28 U.S.C. § 2072. (3) To require additional security: nothing in section 7483 stops the court from requiring the petitioner to post a bond or other security as a condition of review. (4) To impose penalties: the Court of Appeals and Supreme Court can make a taxpayer pay a penalty to the United States if the Tax Court's decision is affirmed and the appeal was mainly meant to cause delay, or the taxpayer's position was frivolous or groundless.