Administrative Finality and the Tax Court of the United States

Abstract

The objectives of this paper are: (1) To review briefly the history of the Board of Tax Appeals and the Tax Court; (2) to trace the increase of its power and influence from its origin in 1924 to its climax in the years 1943-1946; (3) to examine rather thoroughly the dicta of the courts, especially the Supreme Court, on the finality of Tax Court decisions; and (4) to criticize what passes for a solution of the problem of the Tax Court's finality, namely Public Law 773, which became effective September 1, 1948.