Student 1: Why on Earth would anyone litigate $22?!
Student 2: For the principle of it!
Professor: Well. Usually, with the Tax Court, there are several issues that must be resolved, so it's very possible that this was excerpted from the larger case. And usually, when the casebook editor excerpts a case like that they'll include a little asterisk to tell you what else was going on in the case. And since I AM the casebook editor, I think it's safe to say that the casebook editor forgot to do that here.