payment of the underlying tax ordinarily is postponed until the case has been decided. In certain tax disputes involving $50,000 or less, taxpayers may elect to have the case conducted under the Court's simplified small tax case procedure. Trials in small tax cases generally are less formal and result in a speedier disposition. However, decisions entered pursuant to small tax case procedures are not appealable and are not precedential. Cases are calendared for trial as soon as practicable (on a first in/first out basis) after the case becomes at issue. When a case is calendared, the parties are notified by the Court of the date, time, and place of trial. Trials are conducted before one judge, without a jury, and taxpayers are permitted to represent themselves if they desire. However, the vast majority of cases are settled by mutual agreement without the necessity of a trial. However, if a trial is conducted, in due course a report is ordinarily issued by the presiding judge setting forth findings of fact and an opinion. The case is then closed in accordance with the judge's opinion by entry of a decision. Appellate review Either the petitioner (the taxpayer) or the respondent (the Commissioner of Internal Revenue) may take an appeal from an adverse decision of the Tax Court to the appropriate United States Court of Appeals. In the case of an appeal by the taxpayer, a bond is normally required in order to avoid enforcement action during the pendency of the appeal. Instead of taking an appeal, the Internal Revenue Service may issue an "Action on Decision" indicating the Commissioner's "non-acquiescence" in the decision, meaning that the Commissioner will not follow the decision in subsequent cases. In such cases, the Commissioner hopes for the opportunity to litigate the matter in another circuit where he will have a better chance of obtaining reversal on appeal. Judges The Tax Court is composed of 19 judges appointed by the President and confirmed by the Senate. Former judges whose terms have ended may become "Senior judges", able to return and assist the court by hearing cases while serving on recall. In addition, the court is assisted by a number of "special trial judges", who are employees of the court, appointed by the chief judge of the Tax Court, rather than by the President. Special trial judges serve a function similar to that served by United States magistrate