TAXATION-ADMINISTRATIVE LAW-JUDICIAL REVIEW OF DETERMINATIONS OF UNITED STATES TAX COURT-THE RULE OF THE DOBSON CASE

In the field of administrative tax law there is no more intriguing subject for speculation than the scope of judicial review of decisions of the United States Tax Court as sought to be delineated in Dobson v. Commissioner three years ago. The case was a valiant attempt to limit the scope of review of appellate courts by defining the area in which the findings of the Tax Court would be conclusive. The task was an impossible one at the outset because of the lack of standard definition, except at the core, of the flexible and fluid concepts of "findings of fact'' and "conclusions of law." For many, the imposition of this undefined standard on the kaleidoscopic problems of taxation created more confusion than it resolved. The purpose of the decision was to inaugurate a new era in appellate review of matters passed upon by the Tax Court.

The question remains whether that purpose has been or will be achieved through the application of the Dobson case.