During the last two years the Supreme Court of the United States has handed down only five income tax opinions. The box score stands four for the Government, one for the taxpayer. None of the cases involved modifications in fundamental concepts of tax law or resulted in major policy changes in the administration of the fiscal system. The record for the taxpayer is far more impressive in the Congress than it is in the courts. As will be pointed out later Congress rather than the Supreme Court is tending to become the final arbiter in tax disputes. Problems that were traditionally solved by the judiciary are more and more being solved by Congress and this shift has not hurt the taxpayer.
William J. Bowe,
Congress or the Courts as Final Arbiter in Tax Disputes?,
6 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol6/iss1/8