Theses and Dissertations
Date of Award
12-1-2024
Document Type
Dissertation
Degree Name
Doctor of Philosophy (PhD)
Department
Accountancy
First Advisor
Arno Forst
Second Advisor
Haiyan Zhou
Third Advisor
Siamak Javadi
Abstract
This dissertation consists of three interrelated essays on the U.S. Tax Court. The first essay examines the institutional background of the U.S. Tax Court (formerly the Board of Tax Appeals), thereby framing its importance and history. Focused on the factors that gave rise to the Board of Tax Appeals, this essay begins by distilling prior histories and discussing the circumstances that birthed the institution. Next, the paper expounds on early proponents of the Board of Tax Appeals, such as the American Mining Congress and key individuals therein. Specifically, I propose strong influence for the formation of the Board of Tax Appeals from leaders of the American Mining Congress, relying on prosopographical techniques. To conclude, the essay discusses the ongoing importance of the U.S. Tax Court as a primary source of judicial law.
In my second essay, I examine U.S. Tax Court judges, focusing on their individual characteristics and how these characteristics are related to their productivity. Regulators and legal scholars afford considerable interest in improving the U.S. Tax Court. Despite this interest, there is a lacuna of research on U.S. Tax Court judges. The purpose of this essay is two-fold; First, I hand collect and report on the general characteristics and temporal trends of U.S. Tax Court judge characteristics, using the full population of judges since court's inception in 1924; Second, this study investigates whether judge’s individual characteristics affect their productivity. Specifically, I investigate numerous judge characteristics, for example: 1.) education, 2.) sex, 3.) ethnicity, 4.) tenure, 5.) political affiliation, 6.) age, and 7.) senior judge status, and other measures. Overall, my study contributes to the literature by detailing judge characteristics and examining whether systematic variations in these characteristics are associated with judge productivity.
The third chapter examines a sample of corporate petitioners to the U.S. Tax Court. U.S. Tax Court litigation provides a clean measure for aggressive corporate tax avoidance, providing firms that are definitively involved in uncertain tax positions. Using name-matching algorithms, I merge petitioners from a hand-collected database of U.S. Tax Court cases with a sample of U.S. firm fundamentals obtained via Compustat/CRSP. Using this unique sample, and novel proxy for tax avoidance, I examine the relationship between U.S. Tax Court litigation and standard tax avoidance measures used in prior literature, such as effective tax rates (ETRs), book-to-tax differences (BTDs), long-run tax avoidance, DTAX, Wilson (2009)’s SHELTER, and others. Additionally, I investigate whether aggressive tax positions are associated with positive firm outcomes via increased firm value.
Recommended Citation
Sanchez, Rolando Daniel, "One Hundred Years of the U.S. Tax Court (1924-2024): An Examination of the Tribunal, Its Judges, and Firms’ Involvement in Tax Litigation" (2024). Theses and Dissertations. 1661.
https://scholarworks.utrgv.edu/etd/1661
Comments
Copyright 2024 Rolando Daniel Sanchez.
https://proquest.com/docview/3147640547