an Entity references as follows:
Uniformity and jurisdiction in the tax decisions of the United States federal courts. is the ongoing debate spanning many decades about achievement of uniformity and decisionmaking by federal courts when addressing tax controversies against the backdrop of multiple, regionally diverse courts with federal tax jurisdiction. Professor Steve R. Johnson, in part quoting Professor David F. Shores, characterizes the diversity as follows: "'It is difficult to imagine an adjudication system less conducive to uniform decisionmaking than the current fragmented system of federal tax trials and appeals."