See 26 U.S.C.§ 7463(b), which states: "A decision entered in any case in which the proceedings are conducted under this section shall not be reviewed in any other court and shall not be treated as a precedent for any other case."
26 U.S.C.§ 7452. Although, as explained below, the "Commissioner of Internal Revenue" is the proper party to be sued in Tax Court, the statute actually states that the "Secretary" is represented by the IRS Chief Counsel (or delegate). However, the term "Secretary" is defined in 26 U.S.C.§ 7701(a)(11)(B) as the "Secretary of the Treasury or his delegate." Further, the term "or his delegate" is defined (in this context) at 26 U.S.C.§ 7701(a)(12)(A)(i) as "any officer, employee or agency of the Treasury Department duly authorized by the Secretary of the Treasury directly, or indirectly by one or more redelegations of authority [ . . . . ]"
United States Policy and Supporting Positions, page 2. Committee on Homeland Security and Government Affairs, United States Senate, 110th Congress, 2d Session (November 12, 2008). Available: http://www.gpoaccess.gov/plumbook/2008/index.html.
