taken to the United States Court of Appeals for the Federal Circuit. The United States bankruptcy court. Each of the 94 federal judicial districts also has an Article I bankruptcy court which operates under the supervision of the district courts. The bankruptcy courts are broadly empowered to hear any issue arising under the Bankruptcy Code, including federal tax issues arising in bankruptcy proceedings. Professor Johnson reports a growing trend for important questions of substantive tax liability to be decided in bankruptcy proceedings, and since the overwhelming majority of bankruptcy proceedings are voluntary, there is a significant element of taxpayer choice in bringing the tax issues to the bankruptcy courts. Johnson also reports that the bankruptcy courts are seen as "pro-debtor," and have procedural rules that favor litigation of tax issues. Bankruptcy Court appeals are taken to the U.S. District Court before they can be heard by the circuit courts. Diversity in appellate tax jurisdiction For three of these sets of courts, appeals can be taken either by the taxpayer or the IRS to one of the eleven regionally-based U.S. courts of appeals or the United States Court of Appeals for the D.C. Circuit. For the Court of Federal Claims, appeals are to the Court of Appeals for the Federal Circuit, a specialized appeals court, but one with national jurisdiction. With this number of original jurisdiction courts involved in making legal determinations on federal tax matters and thirteen United States courts of appeals exercising appellate jurisdiction, observers recognize and are concerned that the tax laws can be interpreted differently for like cases. As examples, Supreme Court decisions in the well-known cases of Kowalski (whether state policemen could exclude meal reimbursements from gross income) and Dalm (whether a taxpayer could get a refund for overpaid gift taxes otherwise time-barred, when the delay was caused in resolving income tax deficiencies) show the Supreme Court resolving diametrically opposed decisions from two or more of the circuit courts. The Supreme Court, however, accepts few tax cases on appeal, and many cases are not appealed from the circuit courts, allowing diametrically opposed decisions to stand. The diversity also allows forum shopping because a taxpayer can choose to bring a case before any of three, and in a voluntary bankruptcy proceeding, four of the courts of original jurisdiction and can select the court most likely to provide a favorable opinion based on the taxpayer's knowledge of the