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The Internal Revenue Service (IRS) is a unique federal agency because it is subject to the jurisdiction of different trial courts, the two most important of which are the United States Tax Court, a specialized court of limited jurisdiction, and the United States District Court, a court of general jurisdiction. This article offers an exploratory comparison of the tax-case decision-making process of the United States Tax Court and the United States District Courts. Using data from 1996 and 1997, the article examines the differences in decision making of these courts, specifically focusing on expertise and ideology. The United States Tax Court uses its expertise and lack of realistic structural or hierarchical constraints to decide the cases in a far more ideological manner than does the district court; this is consistent with the complexity and political nature of tax assessment and tax collection.

Comparing the Decision Making of Specialized Courts and General Courts: An Exploration of Tax Decisions