generalist judges compared to tax specialists, or a suspicion of a "pro-government" or "pro-enforcement" bias on the part of specialized tax judges, the consensus appears to be that the institutional arrangements for tax jurisdiction are unlikely to be changed to accommodate more uniformity in tax law interpretation. Given that sentiment, it is not clear what forces would drive an initiative for the appellate courts to accord greater deference to Tax Court decisions or otherwise achieve greater uniformity in federal court tax decisions. In the meantime, there will continue to be a robust review of Tax Court and other court of original jurisdiction decisions on tax issues and a diversity of arguments and conclusions for the Supreme Court to consider when it grants certiorari to hear appeals and for Congress when it considers amending the federal tax laws. References United States federal law Taxation in the United States United States tax law