If the decision is not stipulated, is the Tax Court required to issue an opinion giving its reasons for the decision?
What about Fed. R. Civ. P. 52(a), which says that if a judgment is based on fact without a jury, the court has to issue a finding of fact and conclusions of law, unless there is a motion for summary judgment or for judgment on the pleadings?
Contracts / Agreements Lawyer
Surprisingly, no. This is especially the case for smaller matters within a larger overall case. In those situations, as well as sometimes for the whole case, a summary disposition may be sufficient, particularly if it is immediately obvious why the court ruled the way that it did (ie. failure to state a claim, default by one party, etc.) I'd be a bit surprised if there isn't SOME rationale given in the decision (in case of appeal)--such as by citing to a Tax Court rule that explains the decision, but sometimes one or a few sentences are sufficient to dispose of a case or issue.
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To address your question about Fed. R. Civ. P. 52(a), practice and procedure before the Tax Court is governed by the "Tax Court Rules of Practice and Procedure", not the FRCP rules you asked about. In general, Tax Court Rule 152(a) allows the Judge to issue an oral opinion if the Judge is satisfied with the factual conclusions reached and the applicable law is clear.