- 48 - Court should not so accede, particularly without any analysis of those circuit decisions and without some explanation as to why we are departing from our prior decisions. Although this Court is only a trial court, it is a trial court with national jurisdiction. The tax bar, the Internal Revenue Service, and the taxpayers, particularly those residing in the other nine circuits to which Tax Court decisions can be appealed, are entitled to a reasoned, principled explanation of our change of position. The majority not only declines to address the differences in our analyses in our prior cases and those of the Courts of Appeals that have reversed us, but throws out a hint that the result might be different under the recently published regulations, which are effective for the estates of decedents dying after March 1, 1994. Sec. 20.2056(b)-7(d)(3), Estate Tax Regs. This Court's prior decisions are consistent with and support the validity of those regulations. II Venue Issue This is an appropriate case in which to continue to follow our prior opinions since, under the Tax Court's special venue statute, any appeal would lie to the U.S. Court of Appeals for the Seventh Circuit, which has not yet addressed this particular QTIP issue. Although the reviewing court will undoubtedly make its own determination, I think it is appropriate for this Court to address the issue of venue. Brewin v. Commissioner, 72 T.C.Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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