Claude M. Ballard, et Ux. v. Commissioner of Internal Revenue (544 U.S. 40)
U.S. Supreme Court · decided March 7, 2005 · Supreme Court Database (Spaeth)
- Citation
- 544 U.S. 40 · 125 S. Ct. 1270
- Decided
- March 7, 2005
- Term
- October Term 2004
- Vote
- 7–2
- Majority author
- Justice Ginsburg
- Issue area
- Judicial Power
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Ginsburg delivered the opinion of the Court. These cases concern the Tax Court’s employment of special trial judges, auxiliary officers appointed by the Chief Judge of the Tax Court to assist in the work of the court. See 26 U. S. C. § 7443A(a). Unlike Tax Court judges, who are appointed by the President for 15-year terms, see § 7443(b), (e), special trial judges have no fixed term of office, § 7443A(a). Any case before the Tax Court may be assigned to a special trial judge for hearing. Ultimate decision in cases involving tax deficiencies that exceed $50,000, however, is reserved for the Tax Court. § 7443A(c). Tax Court Rule 183 governs the two-tiered proceedings in which a special trial judge hears the case, but the Tax Court itself renders the final decision. The Rule directs that, after trial and submission of briefs, the special trial judge “shall submit a report, including findings of fact and opinion, to the Chief Judge, and the Chief Judge will assign the case to a Judge ... of the Court.” Tax Ct. Rule 183(b), 26 U. S. C. App., p. 1619. In acting on the report, the Tax Court judge to whom the case is assigned must give “[d]ue regard . . . to the circumstance that the [sjpecial [t]rial [j]udge had the opportunity to evaluate the credibility of the witnesses.” Rule 183(c), ibid. Further, factfindings contained in the report “shall be presumed to be correct.”…
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